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Environmental & Social Information Mar 28, 2023

4036_rns_2023-03-28_456f9c50-17e1-492c-a4be-3bdf8f870a45.pdf

Environmental & Social Information

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ENAV GROUP

2022 SUSTAINABILITY REPORT

Consolidated Non-Financial Statement pursuant to Legislative Decree 254/2016

LETTER TO STAKEHOLDERS 4
THE HISTORY OF THE ENAV GROUP 6
THE ENAV GROUP 7
The ENAV Group's identity card and operating model 8
A Safety Culture 12
SUSTAINABILITY GOVERNANCE 14
THE ENAV GROUP'S STRATEGY 15
The 2022-2024 Business Plan 15
The sustainability strategy 16
The 2021-2024 Sustainability Plan 20
THE EU TAXONOMY 21
ECONOMIC PERFORMANCE 25
ECONOMIC VALUE GENERATED AND DISTRIBUTED 26
RUSSIA-UKRAINE CONFLICT 27
1. PLANET 29
THE ENAV GROUP'S ENVIRONMENTAL STRATEGY 29
CLIMATE ENGAGEMENT 31
COMMITMENT TO THE DECARBONISATION OF THE AVIATION SECTOR 32
Flight Efficiency Plan 33
Free Route Airspace Italy 33
Airport Collaborative Decision Making 34
Arrival Management 34
THE COMMITMENT TO DECARBONISATION OF THE GROUP'S ACTIVITIES 35
Carbon Neutrality 2022 35
Science Based Goals to 2030 (SBTi) 35
REDUCTION OF ELECTROMAGNETIC EMISSIONS 43
WASTE MANAGEMENT 44
TECHNOLOGICAL INNOVATION AND DIGITALISATION 45
ENAV GROUP INVESTMENTS 49
ACTIONS RELATED TO THE PROVISION OF AIR NAVIGATION SERVICES 51
THE DEVELOPMENT OF ADVANCED AIR MOBILITY 54
THE FLIGHT INSPECTION SERVICE FOR SAFETY IN THE SKY 56
2. STAKEHOLDERS58
STAKEHOLDER ENGAGEMENT 58
INVESTOR RELATIONS AND FINANCIAL DISCLOSURE 60
ENAV share performance 61
Shareholding structure 62
RELATIONS WITH INDUSTRY ORGANISATIONS, INSTITUTIONS, AND ASSOCIATIONS 63
CUSTOMER RELATIONS 66
THE SUSTAINABILITY NETWORK 68
3. PEOPLE 71
SUSTAINABILITY CULTURE 71
DIVERSITY AND INCLUSION 73
MANAGEMENT AND DEVELOPMENT 76
The selection of new talent 76
Development and enhancement 79
Social policies and corporate welfare 87
OCCUPATIONAL HEALTH AND SAFETY 91
INDUSTRIAL RELATIONS 93
4. GOVERNANCE 96
THE BOARD OF DIRECTORS 98
APPOINTMENT TO AND COMPOSITION OF THE BOARD OF DIRECTORS102
ROLE OF THE BOARD OF DIRECTORS IN MANAGING IMPACTS 103
RESPONSIBILITIES OF THE BOARD OF DIRECTORS 106
CORPORATE INTEGRITY 108
MANAGING RISKS AND OPPORTUNITIES 114
Risks associated with climate change118
REMUNERATION POLICIES121
TAX MANAGEMENT 124
RESPONSIBLE SUPPLIER MANAGEMENT 125
SECURITY MANAGEMENT128
ANNEX 1 – NON-FINANCIAL INDICATORS 130
ANNEX 2 - GRI CONTENT INDEX AND CORRELATION TABLES 157
ANNEX 3 - GROUP MANAGEMENT SYSTEMS, CERTIFICATIONS AND ATTESTATIONS ENAV168
ANNEX 4 – 2021-2024 SUSTAINABILITY PLAN 170
ANNEX 5 - MATERIALITY ANALYSIS, METHODOLOGICAL NOTE AND REPORTING BOUNDARY 175
MATERIALITY ANALYSIS175
NOTE ON METHODOLOGY177
SCOPE OF REPORTING 178

Letter to Stakeholders

For ENAV, 2022 was an important and successful year. After the very difficult period due to the consequences of the COVID-19 pandemic, the year that has just ended was characterised by a decisive upturn in air traffic, which in some periods even exceeded 2019 levels.

But the past year has also been one in which our approach to sustainability has become more solid and mature to the point that it is now the common thread linking all our initiatives. The full integration of sustainability into our strategies and day-to-day actions has enabled us not only to achieve the targets we set ourselves, but also to set additional, particularly challenging ones for 2023-2024.

Following the stabilisation of European performance regulations, the new 2022-2024 Business Plan was approved in 2022, and enhances the ENAV Group's sustainable success guidelines by leveraging its key values: safety, excellence of service quality, people, technological innovation and digitalisation. Correspondingly, the Sustainability Plan was updated, supplementing it with new targets consistent with the Business Plan initiatives and extending its validity until 2024. Finally, in order to define the guidelines for the future, the design of the Future Sky 2031 Plan was initiated.

ENAV's main ESG objective continues to be to make an increasingly decisive contribution to the reduction of aviation emissions, working simultaneously on our direct and indirect emissions, on the sustainable supply chain and on further increasing the production of energy from renewable sources. In this context, while our commitment is constantly focused on the challenges of the future, this is also the time to take stock of what has been achieved so far. Alongside well-established projects such as the Free Route - which this year alone has resulted in lower emissions for carriers of more than 205 million kg of CO2, the year just ended saw the launch of the Arrival Manager (AMAN) on the Rome ACC, a new approach management system that will further reduce CO2 emissions from aircraft arriving. Also in 2022, by virtue of the strategy adopted by ENAV following the approval of our climate targets by the Science Based Target initiative - the first Italian company in the aviation sector - we achieved the reduction of our Scope 1 and 2 emissions by more than 80% compared to 2019. A goal that allows us, with the use of carbon credits to offset the portion of emissions we have not yet managed to reduce, to achieve carbon neutrality. This consolidates a virtuous path that has led ENAV to be recognised among the global leaders in sustainable development in the aviation sector, as also confirmed by the award received at the ATM World Congress 2022 together with NASA and Airbus. As part of this journey, we completed the project to phase out single-use plastics (-7.8 tonnes in 2022) and achieved the 45% target in replacing our car fleet with electric, hybrid and plug-in cars. In line with our targets, we have initiated an action plan for the next few years to reduce our Scope 3 emissions by at least 13.5% by 2030, and we are defining the roadmap to become a net zero company.

But of course our approach to sustainability is not just about environmental protection and climate change mitigation initiatives. In the Social sphere, we gave greater impetus to initiatives aimed at developing an increasingly strong culture of sustainability among ENAV people. Through training sessions, videos and podcasts, we further deepened the topics of diversity and inclusion, occupational health and safety, combating active and passive corruption, and respecting human rights throughout the supply chain, values around which we recognise ourselves as a community of people who act in harmony with the principles of sustainability in their work and in their daily lives. Having obtained ISO 37001 certification from the Parent Company on anti-corruption management systems, the goal we have set for 2023 is to define the path to also obtain certification on gender equality policies according to the UNI/PdR 125:2022 reference practice, certification on diversity and inclusion according to the ISO 56002 standard, and the adoption of the ISO 56002 standard for the management of innovation processes in the Company.

The full commitment of ENAV's Governance, from the Board of Directors to the Board Committees, including the Sustainability Committee, together with the commitment of the top management and all the people of the ENAV Group, has enabled us not only to achieve the objectives identified and to set new and ambitious ones for the years to come, but also to put sustainability at the heart of the Group's strategies, also through

innovation and the digital transformation process underway. Sustainability is now structurally consolidated in compensation policies, with the setting of clear and challenging goals in both short- and long-term incentive policies, and with timely disclosure of these goals and their achievement. These include the commitment to guarantee constant growth in ESG ratings, with particular reference to the CDP (formerly the Carbon Disclosure Project) and Standard and Poor's. With the objective of ensuring constant linearity with the Company's policies in the ESG sphere, and guaranteeing the consolidation of information flows within the Group on the basis of a prospective vision, a Sustainability Management Committee was therefore established.

Our Stakeholders have increasingly become strategic partners in ENAV's growth and together we have travelled, in a coherent and significant way, the pathway towards deeper collaboration to achieve new goals in sustainable development and innovation. And it is precisely technological and digital innovation that today represents for ENAV an inseparable pair with sustainability, being the key factor, together with the talent of our people, to ensure the achievement of the challenging goals of sustainability in the medium and long term.

Our Group is a strategic asset for Italy in the management of airspace, an intangible infrastructure that must be continuously innovated to accommodate, for example, the new means of remotely piloted aircraft, indispensable tools to ensure the development of sustainable mobility. ENAV is a major player in the realisation of this process of modernisation and social evolution, thanks to the professionalism of our people and the push for new cutting-edge dimensions of technology, such as artificial intelligence and the data-driven approach.

A sustainability-centric Group but also a civilised Company, where the value we produce is not only determined by profits, but by the quality of the services we provide, by health and safety, by the impact we have on the environment and on the quality of work and life of our people.

The history of the ENAV Group

ENAV S.p.A. is an Italian joint-stock company that operates as an exclusive supplier of civil airspace management and control services under Italian competence.

The present Company has its origins in the Autonomous Company providing Flight Assistance for General Air Traffic (AAAVTAG), established in 1981. The Autonomous Company took over from the commissariat for flight assistance established three years earlier as the GAT (General Air Traffic) Control Company to manage the passage of part of the air traffic controllers and of airports previously run by the Italian Air Force classified in what was then the Flight Telecommunications Inspectorate (ITAV), a military entity reporting to the Air Force General Staff.

Today the Company is controlled by the Ministry of Economy and Finance (53.3% of the share capital). It operates in a market regulated at European level and provides its services in Italy under the supervision of the Ministry of Infrastructure and Transport (MIT) and the National Civil Aviation Authority (ENAC).

The ENAV Group THE STRUCTURE OF THE GROUP

The ENAV Group's identity card and operating model

ENAV S.p.A. is an Italian joint-stock company that operates as an exclusive supplier of civil airspace management and control services under Italian competence.

ENAV has been listed since 26 July 2016 on the Mercato Telematico Azionario MTA (now EXM - Euronext Milan) managed by Borsa Italiana S.p.A., and is currently the only Air Navigation Service Provider (ANSP) to be listed on the capital market. The majority shareholder with 53.3% of the capital is the Ministry of Economy and Finance (MEF), while 46.7% is floating1 .

The Company operates in a European regulated market and provides its services 2 in Italy under the supervision of the Ministry of Infrastructure and Transport (MIT) and the national regulator ENAC and the National Civil Aviation Authority (ENAC).

ENAV is a key component of the international Air Traffic Management (ATM) system and a major player in the realisation of the Single European Sky, the European Commission's programme to harmonise air traffic management in Europe.

Every day on our routes we accompany those who fly with reliability and safety. We design the sky of the future, investing in people and innovation for sustainable air transport and for Italy's economic growth.

ENAV is the only Italian company that selects, trains and updates professionals working in air traffic control services, guaranteeing safety and punctuality to the millions of passengers flying the Italian skies for over 40 years, contributing to the growth of national and European air transport with efficiency, innovation and respect for the environment.

All of this makes ENAV a company that places sustainability and social awareness at the heart of its business.

1 More information on ENAV's shareholder structure can be found in the "Stakeholders" chapter.

2 The organisation is active in the following main areas: Air Traffic Control Service (ATCS); Flight Information Service (FIS); Aeronautical Information Service (AIS); Meteorological Observation and Forecasting Service, limited to the issuance of meteorological bulletins relating to airports (METAR) and the airspace under its jurisdiction. ENAV's Suppliers mainly consist of companies supplying goods, services and works that accompany the Company from its selffunctioning activities to its core air traffic control activities (by way of example, the supply of hardware and software components that feed into the technological infrastructure serving air traffic control, the supply of telecommunications systems, the purchase and maintenance of electronic equipment, maintenance services for Aeronautical Ground Lights, etc.).

In 2022 more than one million planes flew over Italian airspace were and ENAV, with its 4,185 employees, guaranteed 24/24 safety and punctuality hours, providing all air navigation services to aircraft.

From its air traffic Control Towers at 45 airports, ENAV manages the take-offs, landings and ground movements of aircraft, and from its 4 Area Control Centres it provides navigation assistance to all en-route traffic, whether for overflight or for landing at one of Italy's airports.

Long considered one of Europe's "big five" in terms of operational performance and innovation, the ENAV Group is now at the forefront of environmental support thanks to the constant optimisation of routes to reduce aircraft consumption and the use of innovative technologies to improve the efficiency of its infrastructure.

The Operating Model

ENAV ensures navigational assistance to all aircraft, whether for overflight or for landing at one of Italy's airports, by means of:

  • the 4 area control centres (ACC) in Rome, Milan, Padua and Brindisi for the en route phase;
  • the 45 air control towers at 45 civilian airports in Italy for the take-off, landing, and ground movement of aircraft: Fiumicino, Malpensa, Linate, Venice Tessera, Bari, Bologna, Catania, Ciampino, Naples, Olbia, Orio al Serio, Palermo, Turin Caselle, Verona Villafranca, Alghero, Brindisi, Cagliari, Florence, Genoa, Lamezia Terme, Rimini, Ronchi dei Legionari, Treviso, Parma, Turin Aeritalia, Albenga, Cuneo, Brescia, Bolzano, Padua, Venice Lido, Perugia, Ancona Falconara, Forlì, Rome Urbe, Pescara, Rieti, Salerno, Reggio Calabria, Comiso, Pantelleria, Lampedusa, Grottaglie, Crotone, Foggia.

Air traffic control is guaranteed seamlessly, from the moment an aircraft's engines are turned on in the apron of the airport of departure, until they are cut once it arrives at the apron assigned at the airport of destination. The task of the air traffic controller is to guarantee safe and expeditious movement of aircraft by ensuring a minimum separation between aircraft of 5 miles on the horizontal plane (reduced to 3 NM in the vicinity of the airports of Fiumicino, Ciampino, Linate, Malpensa and Bergamo) or 1,000 feet in the vertical plane. Flight efficiency objectives are met through fast movement, assigning the most direct route possible between the airport of departure and the airport of destination and ensuring the ideal climb and descent profile, i.e. the one that facilitates the lowest possible fuel consumption and the consequent reduction of the environmental footprint thanks to the lower CO₂ emissions.

A Safety Culture

ENAV considers the operational safety level of air traffic control and air navigation services an essential priority. The same applies to operating efficiency and the seamless availability of installations, systems and software used to that end.

Just Culture Policy Safety Policy
The Just Culture Policy is a fundamental
and enabling element of the Safety
incident reporting system.
By adopting a "No Blame" approach - i.e.
accepting honesterror without penalising
it in any way - a climate of mutual trust
and free circulation of information useful
for the prevention of Safety events is
guaranteed.
The Safety Policy is the formal declaration
by which ENAV ensures a clear definition
of the responsibilities for Safety, together
with the role of the resources involved in
Safety-related activities and their
possession of the necessary skills and full
awareness of the tasks they are called
upon to perform.

In compliance with the requirements of Regulation (EU) No. 373/2017, ENAV has adopted a Safety Management System (SMS) with which it ensures a formal, explicit and proactive approach in the systematic management of Safety.

As a preventive measure, it has set up a quantitative safety risk assessment system. This approach, which complies with the ATM/ANS service certification regulation, is based on the definition of certain risk models that allow the impact of changes to the ATS system (people, procedures and equipment) on safety levels to be assessed and the risks of each individual Territorial Unit to be identified and monitored.

In a reactive perspective, on the other hand, each safety event reported in accordance with the EU regulations on the subject3 is duly analysed in order to identify possible "safety proposals" which, addressed to the relevant ENAV organisational structures, are then translated into "remedial action" or "improvement proposals".

3 EU Regulation 376/2014 on occurrence reporting, analysis and monitoring in civil aviation.

Finally, in order to guarantee the highest safety levels ENAV monitors the safety of ATM/ANS services and the state of the Safety Management System with the aim of identifying any negative trends so that timely and effective corrective actions can be taken.

Interventions in 2022 in the field of Safety

Below are the main activities in the field of Safety in 2022:

  • the analysis of approximately 4,960 Safety occurrences which, via a Safety Dashboard implemented during the year, are presented in real time to operational management, enabling monitoring of Safety performance;
  • through the conclusion of the second phase of the NOSS (Normal Operations Safety Survey) project at the Padua Area Control Centre and the start, in December 2022, of the third phase of the project at the Milan and Brindisi Area Control Centres, thanks to the training of 11 Air Traffic Controllers who will carry out observation activities at these centres. The NOSS is a methodology that analyses performance in terms of Safety, using observations in "normal operations" mode to identify the strengths and weaknesses of the air traffic management system;
  • conducting a "cross-border Safety Survey" between ENAV and AUSTROCONTROL for a joint assessment of the coordination procedures defined between ACC Padua and ACC Vienna through observations and interviews (with particular attention to "work as done"), in order to identify any safety criticalities and "best practices" used by the two entities;
  • hand-out to all Group employees of a Safety Culture Survey, according to the methodology established by EUROCONTROL, which made it possible to assess the safety culture of the entire organisation (not only of operational staff) in order to identify its strengths and weaknesses. The activity will conclude with the development of a three-year Action Plan to address the aspects of Safety Culture that were identified as weaker.

Sustainability governance

Sustainability permeates all of ENAV's strategic management activities with a view to integrating ESG issues into the business, as expressly enshrined in the Corporate Governance Code, which gives the Board of Directors the role of guiding the Company's sustainable success.

The Board of Directors approves the Sustainability Plan, which includes the relevant projects in light of the Group's industrial strategy, together with this document, which includes, inter alia, the contents required for the Consolidated Non-Financial Statement (NFS) pursuant to Legislative Decree 254/2016.

In carrying out these tasks, the Board of Directors is supported by the Sustainability Committee, which covers relevant advisory duties on sustainability issues as well as monitoring functions both on ESG reporting and related strategies. In particular, in addition to expressing opinions on specific sustainability issues, the Sustainability Committee examines the general approach of this document, proposed by the Chief Executive Officer, and the structure of its contents, as well as the completeness and transparency of the information provided through it, issuing a prior opinion to the Board of Directors.

This vision, as indicated by best practices, is obviously extended to topics of compensation. The variable compensation, for the Chief Executive Officer and Top Management, consolidates an integration vision in which business is compensated by the progressive perfection of actions that are important from a nonfinancial point of view. The variable incentive system, approved by the Board of Directors on the proposal of the Remuneration and Appointments Committee, is approved or rejected by a binding vote of the Shareholders, contemplating long-term objectives together with projects of more immediate relevance.

Moreover, in December 2022, the ESG Steering Committee was formed in response to the increased strategic importance of incorporating sustainability into corporate governance and Business Plan initiatives. It comprises all unit heads reporting directly to the CEO, 4 the Chief of Sustainability and CSR, and the Sustainability Committee Secretariat. It seeks to develop corporate structure collaboration on ongoing efforts and the objectives of the 2021-2024 Sustainability Plan, as well as to maintain a continual flow of information on ongoing operations, guidelines, and regulatory changes in the industry.

Company governance ensures, further, that the integration of relevant ESG issues into the business is constantly monitored also from a risk perspective, thanks to the Internal Control and Risk Management System (ICRMS) and the oversight that the Control, Risks and Related Parties Committee ensures in this area in supporting the activities of the Board of Directors. In accordance with the Corporate Governance Code, this latter Committee is in fact responsible for assessing the suitability of periodic financial and non-financial information to represent correctly the Company's business model, strategies, the impact of its activities and

4 Due to the organisational competences assigned to them, the corporate resources that make up the ESG Steering Committee are assigned responsibility for implementing the Company's ESG commitments.

the performance achieved, as well as examining the content of periodic non-financial information relevant to the ICRMS. Finally, in addition to the entire ICRMS, the Board of Statutory Auditors also has the task of overseeing the non-financial disclosure5 .

The ENAV Group's strategy

The 2022-2024 Business Plan

In a scenario of progressive recovery of pre-pandemic traffic volumes, the ENAV Group defined the new 2022- 2024 Business Plan and launched the Future Sky 2031 Plan, approved by the Board of Directors at its meeting on 12 May 2022.

The Plan enhances the factors that characterise the sustainable development of the ENAV Group, leveraging its key values of safety, excellence in the quality of services rendered, human resources, technological innovation and digitalisation. The Plan describes the strategic objectives to be achieved during the period under review, broken down into six strategic pillars, assessing the economic, equity and financial projections of the results of the individual Group entities. The first three vertical pillars, directly related to the Parent Company's operations, focus on technological and operational excellence, digital transformation and commercial repositioning. The other three pillars represent a series of transversal actions that intersect the three vertical pillars and focus on the centrality of people, which will make it possible to generate long-term value for all Stakeholders with positive impacts for the sector and the entire supply chain to the benefit of the Italy's regions and economy. The main projects and their status as of 2022 are outlined below.

Technical operational excellence

The fulcrum of the Business Plan is the new technical-operational model, which aims to increase productivity and flexibility of the national airspace and air traffic control structure, to the benefit of airlines, passengers and the Italian economic system in general. The new model is based on three fundamental structural rationalisation measures for more efficient service delivery:

  • the consolidation of the Radar Control Centres (ACC Area Control Centres) with the change from 4 to 2 ACCs, located in Rome and Milan;
  • the upgrading of the Brindisi and Padua ACCs, converted into Remote Tower Control Centres (RTCC) among the most important in Europe – for the remote control of 13+13 low-traffic airports, with 24/7 operations, to the benefit of the local economies, both in terms of tourism and freight transport. The first Local Digital Tower was opened in Brindisi on 13 June 2022, while the preparatory activities for the implementation of the Local Digital Towers in Perugia and Parma, scheduled for 2023 and 2024 respectively, have begun;
  • the integration of eleven approach services (APP), today provided by the airport towers, into their respective Area Control Centres (ACC). With the integration in pre-summer 2022 of the Naples approach on Rome ACC, 5 of the 11 planned interventions have been completed, 3 more will be completed in 2023.

The path of technological innovation finds its realisation in the new Flight Data Processing tool ''Co-flight'' and in the new ATM (Air Traffic Management) platform ''4-Flight'', two technological platforms that, by renewing the existing ones in operation for more than 20 years, will allow greater capacity, flexibility and scalability of the Italian airspace and its air traffic control system, necessary to manage the expected increase

5 Further information on sustainability governance can be found in the chapter "Governance".

in traffic forecast for 2031 (+15/20% against the 2019 record). For both platforms, the planned software releases in 2022 have been completed.

In December 2022, the Technical Operation Centre (TOC) in the Ciampino ACC came into operation, implementing a new maintenance management model. The new facility allows the remote supervision and management of maintenance activities of ground systems (e.g. radar, towers, landing guidance, etc.) located throughout the country, which now manages more than 47,800 devices.

Digital Innovation

The ENAV Digital path launched in 2021 aims to promote the digital transformation of ENAV's management systems through process innovation, information systems and enabling technologies, such as big-data availability, AI, Machine Learning and IOT. The Group also undertook the unification and migration of its management systems to the cloud. The new corporate ERP went into operation at IDS AirNAV in December 2022, and preparatory activities for the transition of the other Group Companies to take place in 2023 and 2024 were commenced.

In addition, the first Open-Innovation initiative materialised with the ENAV Thinking Cup 2022, held in Forlì on 22-24 September, focusing on Unmanned Traffic Management and Advanced Air Mobility.

Commercial development

The ENAV Group is present with its systems and services in about 100 countries. In 2022, the Group recorded new orders worth more than €31M, in line with 2021 and an increase in its turnover in the unregulated market of more than 35% compared to 2021, with further significant prospects of strengthening in 2023- 2024.

Of particular note are the maintenance of the position in almost all geographical areas, the acquisition of a significant project in the Middle East with the Qatar Civil Aviation Authority aimed at supporting the FIFA World Cup 2022 and the start-up of the new FIR in Doha, and the acquisition of the first technology supply orders in "As A Service" mode in line with the strategy set out in the Business Plan for the third market. Also worth mentioning is the start of the first projects in the UTM sector, for the development of complex operations that will allow the definitive development of the drone market in Italy.

ENAV People

Personnel is a key factor for the ENAV Group. Putting industry back at the centre means focusing on young people, on talent and on new digital skills.

In 2022, some 400 people (more than 50% of whom are under 30 years of age) were employed within the Group and induction processes on key SW development topics were initiated.

In the important process begun, special attention is paid to the inclusion of resources with an innovationoriented digital mindset.

The sustainability strategy

Taking up the challenge laid down by the UN 2030 Agenda for Sustainable Development and aware of the urgency posed by the climate crises, the ENAV Group had already started a change management process in the three-year period 2018-2020 by placing sustainability at the heart of its mission and its relations with its Stakeholders.

If in the 2018-2020 Sustainability Plan, indeed, the Company had set itself a series of objectives aimed mainly at laying the foundations for creating a new culture of sustainability among people to consolidate sustainability governance and initiate ESG projects that can build the foundations for the future, the 2021- 2023 Sustainability Plan, supplemented then, in 2022, with new objectives and extended until 2024, has allowed the Group's sustainability strategy to be consolidated through the definition of a road map that aims to lead ENAV to play a leading role in the sustainable development of the entire air transport sector.

The complete integration of sustainability into business strategies, the consolidation of governance, entry into ESG ratings, projects in diversity and inclusion and the commitment to decarbonisation with the consequent validation of our strategy on CO₂ emissions by the Science Based Target initiative (ENAV was the first company in the Italian air transport sector and the first service provider in the world to achieve this important milestone) and the reduction of Scope 1 and 2 emissions by approximately 75% compared to 2021), are just some of the results achieved in 2022 which paved the way for an increasingly challenging path rich with objectives that we aim to achieve together with all ENAV people and our Stakeholders.

OUR PATH TO VALUE CREATION

Starting in 2017, ENAV's path towards sustainability, in addition to being in line with what is defined in Legislative Decree 254/2016 has been increasingly transformed into a process of value creation and of the integration of sustainability in business strategies. This is a process which, even in the difficult period of the pandemic, has never ceased, but has been pursued, rather, with renewed vigour.

2017:

  • Non-Financial Statement 2016, for internal use only
  • Assessment and definition of the system of non-financial reporting
  • Stakeholder Engagement 2017 and Materiality Matrix

2018:

  • Consolidated Declaration of a Non-Financial Character 2017
  • Integration of ESG risks in the Enterprise Risk Management
  • Constitution of the Sustainability Ambassadors group
  • Networking: ENAV joins "CSR Manager Network"
  • Networking: ENAV takes part in the "Salone della Sostenibilità"
  • Creation of the internal Sustainability Committee
  • Multi-Stakeholder workshop 2018
  • "Anti-corruption" policy
  • Sustainability Plan 2018-2020
  • First Sustainability Day
  • Internal ERP (Enterprise Resource Planning) system for quantitative data reporting

2019:

  • Insertion of ESG KPIs into the MBOs of top management
  • From the Consolidated Declaration of a Non-Financial Character to the Sustainability Report 2018
  • Brand Identity: Sustainability logo
  • Sustainability site: new web platform
  • "Diversity and Inclusion" policy
  • LinkedIn: creation of "Sustainability ENAV" page
  • Corporate Sustainability Assessment
  • Stakeholder Engagement
  • University of Pavia: first prize "Best Sustainability Report"
  • Italian stock exchange: first participation by ENAV in the Sustainability Week

2020:

  • Biblioteca Bilancio Sociale (Social Responsibility Library): first prize for "The Sustainability Path"
  • Networking: ENAV enters the Executive Committee of the "CSR Manager Network"
  • Calculation of the Company's carbon footprint and Carbon Neutrality 2022 objective
  • Integrated Governance Index 2020: ENAV is third in the special industry sector classification
  • "Electric mobility" project
  • ESG impact evaluation
  • German Institute of Quality and Finance: prize for "Italy's best employers for women"
  • "Human Rights" policy
  • "Environmental" policy
  • First Sustainability Loan
  • From Stakeholder Engagement to Stakeholder Management
  • The "Plastic free" project
  • Digital Sustainability Day

2021:

  • Networking: ENAV joins the "United Nations Global Compact"
  • Preparation of the Sustainability Plan 2021-2023
  • ENAV takes part in "Sodalitas Call for Future"
  • ENAV enters the "Green Star Sostenibilità" classification of the ITQF (German Institute for Quality and Finance) and of the Italian national daily La Repubblica
  • ENAV enters the "Leader della Sostenibilità" classification of the Italian finance daily Sole 24 Ore
  • ENAV receives the "Health Friendly Company" award from the Honda Foundation
  • The "Improve Yourself" project dedicated to people with disabilities
  • ENAV joins the Science Based Target initiative (SBTi)
  • The "Diversity Assessment for Inclusion" project

• Expansion of the Group's Sustainability Ambassadors throughout Italy

2022

  • Launch of AWorld APP
  • "Green Star Sostenibilità" award of the ITQF (German Institute for Quality and Finance) and of the Italian national daily La Repubblica.
  • Reduction of Scope 1 and 2 emissions by about 75% compared to 2021
  • Consolidation of the supplier assessment process against ESG criteria
  • Obtaining CDP and Standard and Poor's rating
  • Launch of the Arrival Manager (AMAN) system at Roma Fiumicino, which will allow a considerable reduction in CO2 emissions by aircraft arriving
  • Achievement of the electromagnetic emission reduction target by decommissioning 50% of NDBs (Non-directional beacons) used for instrument air navigation
  • Reaching the 45% target of replacing the car fleet with electric/hybrid/plug-in vehicles.
  • Achievement of the targets, set out in the Sustainability Plan, related to self-production of energy from renewable sources and consumption efficiency

The 2021-2024 Sustainability Plan

In light of the results achieved and the new challenges that the Company has decided to set for itself in the long but also in the short term, the Sustainability Plan was updated in 2022 to ensure perfect alignment with the time horizons of the Business Plan, integrating new objectives and extending its validity until 2024.

The 2021-2024 Plan, like the 2021-2023 Plan, is based on the 17 Sustainable Development Goals (SDGs) set by the United Nations and is directed within the established perimeter of strategic development lines, defining a series of measures that draw inspiration from several fields, including: (i) the Group's materiality; (ii) the findings of Stakeholder management activities; (iii) an analysis of the ENAV Group's positioning with respect to assessments conducted on some important sustainability indices and (iv) a benchmark analysis on sustainability issues of greatest interest to the market and the Group.

The structure remains articulated on 6 pillars, namely: (i) Strategy and Governance, (ii) Policies, (iii) Technological Innovation, (iv) Reporting and Communication, (v) Culture and Dedicated Projects, and (vi) Climate Change. It also includes 32 objectives that represent the main projects on which the Company will be engaged in the two-year period 2023-2024.

As for the new projects planned for 2023 and 2024, these concern:

  • ➢ the "Strategies and Governance" pillar, for the development of a model for measuring the economic, social and environmental impacts generated by strategic sustainability initiatives;
  • ➢ the "Policies" pillar, for the maintenance of ISO 37001 and ISO 45001 certification; obtaining EASI (Integrated Sustainability Corporate Ecosystem) certification; the feasibility assessment for the adoption of the ISO 56002 standard for the management of innovation processes in the Company; the feasibility assessment for certification according to the UNI/PdR 125 Reference Practice: 2022 (Gender Equality Policies); to the feasibility assessment for certification according to ISO 30415:2021 (Diversity & Inclusion);
  • ➢ the "Technological Innovation" pillar, for the development of research and innovation activities related to the SDGs; for research and development of artificial intelligence and machine learning algorithms, to be executed in High Performance Computing cloud environments, functional to the Group's core and non-core activities and to sustainability issues;
  • ➢ in the "Reporting and Communication" pillar, to the development of materiality analysis according to the "Double Materiality" concept; to the elaboration of the GHG Report; to the further impetus of external communication on sustainability issues; to the dissemination of sustainability issues to new generations through a "Generational Report"; to the integrated reporting of corporate performance;
  • ➢ in the "Culture and Dedicated Projects" pillar, to the acquisition of new talent with sensitivity to ESG issues;
  • ➢ the "Climate Change" pillar includes the further reduction of electromagnetic energy transmitted through optimisation on navigation instruments; the further replacement of the car fleet with electric-hybrid-plug-in cars; the development of new projects aimed at energy efficiency; the improvement of the reporting process of Scope 3 emissions - capital goods; the definition of a new approach to the Circular Economy; the definition of the impacts of climate change on ENAV's business; the strategy aimed at achieving SBTi Scope 1 and 2 objectives by 2030; the definition of the strategy aimed at reducing Scope 3 emissions by 13.5% by 2030.

Each objective is articulated by referring it to one or more units responsible for achieving it and is accompanied by KPIs, which define its measurability and targets that allow its achievement within the reference period to be verified.

For a more in-depth and comprehensive analysis of all the Plan's objectives, please refer to Appendix 4.

The EU Taxonomy6

The EU Taxonomy Regulation (Regulation EU 852/2020 of 18 June 2020) provides a unified system of classification of economic activities that can be considered eco-sustainable.

Specifically, for the purposes of this Regulation, to qualify as environmentally sustainable (or "ecosustainable"), an economic activity must jointly meet a series of conditions:

  • make a substantial contribution to one or more of the six environmental objectives7 referred to in Article 9 of the Regulation;
  • comply with the technical screening criteria laid down by the Commission for each individual environmental objective;
  • comply with the principle of "Do Not Significant Harm" to other environmental objectives;
  • be carried out in compliance with the minimum social safeguards (in line with the OECD Guidelines and the United Nations/ILO Guiding Principles on Economic Activities and Human Rights).

Pursuant to the regulatory requirements set out in the Delegated Act relating to Article 8 of EU Regulation 2020/852, the ENAV Group is required to include in its Non-Financial Statement information on how and to what extent its activities are associated with eco-sustainable economic activities pursuant to the EU Taxonomy Regulation.

For this second year of application, a disclosure should be prepared that includes the share of taxonomyaligned and taxonomy-not-aligned economic activities (or "Taxonomy – Aligned/Not Aligned"), relative to turnover, capital expenditure and total operating expenditure incurred.

The following paragraphs outline the ways in which the ENAV Group assessed compliance with Regulation (EU) 852/2020 and the prospectus with the quantitative KPIs requested.

With regard to the roadmap set by the European Commission, at the date of publication of this document only the Delegated Acts relating to the first two environmental objectives (climate change mitigation and adaptation to climate change) have been published, providing a description of the economic activities eligible for the EU Taxonomy Regulation and the technical screening criteria related thereto. Therefore, the scope of analysis and the data included in this disclosure refer only to these two objectives.

ANALYSIS OF ELIGIBLE ACTIVITIES

The evaluation process to determine the eligibility of economic activities began in 2021. Specifically, to determine the eligibility of economic activities, both the "Statistical classification of economic activities in the European Community" (Nomenclature of Economic Activities - NACE) 8 and the descriptions of the activities reported in Annex I and Annex II of the Climate Delegated Act were analysed.

6 In compliance with the European common enforcement priorities for 2022 annual financial reports, issued by ESMA on 28 October 2022.

7 a) climate change mitigation; (b) adaptation to climate change; (c) sustainable use and protection of waters and marine resources; (d) transition to a circular economy; (e) prevention and reduction of pollution; (f) prevention and reduction of pollution.

8 The NACE code is a general classification system used to systematise and standardise the definitions of the economic and industrial activities of the Member States of the European Union. The classification was first introduced in 1970 and then revised over the years, until the most recent review with Regulation (EC) 1893/2006. Each national statistics office has formulated a conversion table to which reference is made to translate NACE codes automatically at national level. Italy's national institute of statistics, ISTAT, translates NACE (Nomenclature of Economic Activities) codes with ATECO (ATtività ECOnomiche) classifications.

On the basis of the interpretation of the requirements applicable, the ENAV Group has assessed that its main activities are not among those identified to date by the reference legislation for the two environmental objectives of Climate Change Mitigation and Climate Change Adaptation, set out respectively in Annex I and II of the Climate Delegated Act.

This assessment focused on issues related to 6.17 "Low-carbon airport infrastructure", 9.1. "Research, development and innovation close to the market" and 9.2 "Research, development and innovation for the direct capture of CO2 directly into the atmosphere".

The findings of the analysis were also confirmed for 2022, whereby the ENAV Group has no eligible activities and consequently none aligned with the Taxonomy.

In light of these considerations, the KPIs provided for by the EU Taxonomy Regulation were calculated, developing a preliminary analysis that also took into account the investments and operating expenses related to the purchase of outputs from economic activities eligible for the Taxonomy and/or relating to the measures implemented that allow energy efficiency of buildings.

METHODOLOGY FOR CALCULATING THE KPIS PROVIDED FOR BY THE EU TAXONOMY REGULATION

To calculate the KPIs required pursuant to the Taxonomy Regulation and the additional applicable regulatory references9 , as described below, the ENAV Group carried out an analysis of turnover, investments and operating expenses for the 2022 financial year.

For the turnover portion10

For the calculation of the turnover indicator, the denominator was consolidated net sales in accordance with IAS 1.82(a). With regard to the numerator, on the basis of the considerations mentioned above and the interpretation of the EU Taxonomy Regulation, no share of turnover obtained from the sale of products or services associated with economic activities considered eligible in relation to the objectives of Climate Change Mitigation and Adaptation to Climate Change has been identified.

For the portion of eligible capital expenditure11

▪ Numerator: increases in fixed assets related to the purchase of outputs from Taxonomy-Aligned economic activities and/or related to the measures put in place that make possible a reduction of emissions into the atmosphere. In the case of the ENAV Group, investments related to energy efficiency were mainly considered, including the restructuring of buildings and real estate and the renovation of the new data centre. In 2022, eligible investments amounting to €1,457,435.05 were identified, resulting in a ratio of about 1.8% on CapEx as defined below.

9 The analysis and methodology for calculating the KPIs were carried out with particular reference to the interpretation of the information defined in Annex I of the Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament of the Council and of the document "Draft Commission notice on the interpretation of certain legal provisions of the Disclosures Delegated Act under Article 8 of the EU Taxonomy Regulation on the reporting of eligible economic activities and assets" published on 2 February 2022. 10 The financial data included in this KPI correspond to the Group's net revenues included in the Annual Report at 31 December 2022: Consolidated Financial Statements.

11The financial data included in this KPI correspond to the increases in fixed assets included in the 2022 Annual Report: Consolidated Financial Statements.

▪ The denominator took into account increases in property, plant and equipment and intangible assets, gross of depreciation and any remeasurements, including those resulting from revaluations and impairments, for the year in question, and excluding changes in fair value.

For the portion of eligible operational expenditure12

  • With regard to the numerator, the costs included in the denominator relating to the purchase of outputs from Taxonomy-Eligible economic activities and/or relating to the measures put in place to reduce emissions into the atmosphere were considered eligible. Specifically, the costs related to energy efficiency and the reduction of energy consumption of buildings were included. However, no eligible operational costs were identified.
  • At the denominator, total direct non-capitalised costs relating to research and development, building renovation measures, short term and variable rentals, maintenance and repair, and any other direct expenditure related to the day-to-day maintenance of property, plant and equipment, either by the Company or by third parties to whom these tasks are outsourced, necessary to ensure the continuous and effective operation of these assets were taken into account. Expenses related to the daily operation of property, plant and machinery, such as raw materials, the cost of employees operating the machine, and electricity or fluids necessary for the operation of these assets were excluded.

12 The financial data included in this KPI are comprised in the consolidated operating costs contained in the 2022 Annual Financial Report: Consolidated Financial Statements.

RESULT OF THE ANALYSIS CARRIED OUT

Substantial contribution criteria Do Not Significant Harm' (DNSH) Criteria
Economic activities (1) (s)apon Absolute CapEx (3)
Currency
Proportion of CapE (4)
0/0
Climate change mitigation (5)
0.6
Climate change adaptation (6)
06
Water and maine resources (T)
04
Circular economy
(g) .
0/6
(6) ແຜນກາງງາມຈ
06
Biodiversity and ecosystems (10)
0/0
(II) ແດ່ມຂອງກຸນພາ ລັບຮຸບວ ລາຍໝຸງ
YN
Climate change adaptation (12)
SN
(8) Ster and marine resources (13)
Y/N
Circular economy (14)
Y/N
Pollution (15)
Y/N
Biodiversity, and ecosystems (16)
Y/N
(LI) sp.16nSafes umuiuiIM
Y/N
Taxonomy
aligned
proportion of
CapEx
Year 2022 (18)
Percent
Taxonomy
aligned
proportion of
CapEx
Year 2021 (19)
Percent
Category
(enabling
activity) (20)
Category
(transitiona
l activity)
(21)
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities
(Taxonomy-aligned)
A.1. Environmentally sustainable activities
(Taxonomy-aligned) (A.I)
0,00 € 0% 0%6 0% NA NA NA NA NA NA NA NA NA NA NA 0% 0%6 T
A.2 Taxonomy-Eligible but not environmentally
sustainable activities (not Taxonomy-aligned
activities)
Activity1 4,19 470,929.04 € 0.59%
Activity 2 1,3 22,670.96 € 0.03%
Activity 3 7,6 816,464.05 € 1.02%
Activity 4 8,1 147,371.00 € 0.18%
CapEx of Taxonomy-eligible not but not
environmentally sustainable activities (not
Taxonomy-aligned activities) (A.2)
Total (A.1+A.2) 1,457,435.05 € 1.8%
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
B. TAXONOMY NON-ELIGIBLE ACTIVITIES
Capex of Taxonomy-non-eligible activities (B) 78,299,213.93 98.2%
Total (A+B) 79.756.649 € 100%
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
Opex of Taxonomy-non-eligible activities (B) 672.122.565 100%
Total (A+B) 672,122,565 100%
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
Turnover of Taxonomy-non-eligible activities
(B)
952.780.248 100%
Total (A+B) 952,780,248 100%
Taxonomy-Eligible activities Taxonomy-Not Eligible activities
Turnover portion 0% 100%
Portion of capital expenditure 1.8% 98.2%
Portion of operational expenditure 0% 100%

Considering the evolving nature of the regulation and pending the publication of further Delegated Acts relating to the other environmental objectives set forth in the regulation, ENAV plans to follow its developments and carry out, where necessary, further in-depth analyses and updates of the information.

Economic performance

Economic value generated and distributed

Through its activities, the Group generates benefits for its Stakeholders.

In 2022, the Group generated €992.1 million in economic value, an increase of 11.9% compared to 2021 as a result of the full resumption of the air transport business. Although air traffic has not yet fully returned to pre-crisis levels, the economic value generated by the Group is up by 4.6% compared to 2019 values.

86.7% of the economic value generated was distributed and 13.3% was retained.

With regard to the economic value distributed, it should be noted that:

  • 17.8% relates to operating costs incurred for the purchase of goods and services benefiting the Group's suppliers.
  • 63.2% was distributed to employees in the form of salaries, social contributions and bonuses.
  • 13.6% was distributed to providers of risk capital and financing as dividends and remuneration of loan agreements entered into.
  • 5.3% was distributed to government authorities for direct and indirect taxes.
  • 0.1% was distributed to the community.

Economic value directly generated and distributed (in €/mln)

2022 2021 2020
Economic value generated 992,090 886,633 811,060
Economic value distributed (860,156) (732,262) (607,979)
Operating costs (153,645) (140,203) (124,887)
Value distributed to employees (543,979) (499,241) (460,957)
Value distributed to capital providers (116,680) (65,297) (7,943)
Value Distributed to the Government (45,217) (26,829) (13,254)
Value distributed to the community (635) (692) (938)
Economic value retained (131,934) (154,371) (203,081)

Included in the value distributed to capital providers is the 2022 dividend to be distributed to Shareholders, proposed to the Board of Directors and subject to the approval of the Shareholders' Meeting of 28 April 2023.

Russia-Ukraine conflict13

The offensive action taken by the Russian government against Ukraine, has wrought changes in the geopolitical balances and inevitable repercussions on the global macroeconomic framework are evident.

As a result of the sanctions consequently applied by the European Union states against Russian natural and legal persons, the Group immediately took steps to examine this sanctions regime, including the restriction on the financial and capital markets of the European Union, the closure of air space to carriers traceable to the Russian Federation, and the restrictions on the export of goods, services and technologies, in order to verify the impact on its business and to take any appropriate initiative aimed at ensuring full compliance with the sanctions policy.

In 2022, the Group fully wrote off open positions with customers belonging to the Russian Federation amounting to €0.7 million and has no further outstanding relations with nations within the scope of the conflict. In the global context, the continuing conflict between Russia and Ukraine is generating impacts on raw material supplies and significant increases in energy prices. Furthermore, inflationary pressure has begun to show the first significant signs of rising prices of various cost natures. In 2022, the ENAV Group recorded a significant increase in the costs associated with energy procurement; however, due to the Group's business model and the EU regulations to which the Parent Company is subject, which, in particular, allow for the recovery of the variation of inflation with respect to the forecast figure through the balance mechanism, no significant risks in terms of inflationary effects are foreseen. Furthermore, with reference to the possible effects of the shortage of electronic components, at present there are no critical issues in the supply chain with negative impacts in terms of business continuity. In addition, the Group holds an adequate back-up stock of materials necessary for the operational systems supporting its business, such that any delays in the supply chain are contained. The Group continues to monitor the impact on its business and to take all appropriate steps to ensure full compliance with the sanctioning regime adopted by the European Union states and to promptly identify possible consequences on its current and prospective business in view of the ongoing critical nature of the scenario.

With reference to the above, the Group has no significant impact on the main alternative performance indicators14 and no impact is foreseen on expected cash flows as depicted in the approved Business Plan.

13 In compliance with the European common enforcement priorities for 2022 annual financial reports, issued by ESMA on 28 October 2022.

14 For alternative performance indicators, please refer to the Annual Financial Report 2022.

1. Planet

The ENAV Group's environmental strategy

Aware of its role in the Italian economy, the ENAV Group has long been committed to reducing the environmental impact of its activities and considers the protection of the planet to be an essential objective.

Considering the operating model adopted, the environmental impacts directly generated by the ENAV Group's activities are attributable to the use of electricity for the operation of the technological infrastructure and Company premises and, to a lesser extent, fuel consumption.

Environmental impacts of the ENAV Group

  • climate-changing emissions, generated by:
    • o electricity consumption for the operation of the ENAV Group's technological infrastructure and sites.
    • o fuel consumption for air conditioning in offices and operations centres.
    • o fuel consumption of the car and air fleet owned by the ENAV Group and used for the radiological service.
    • o activities upstream and downstream in the value chain.
  • electromagnetic emissions produced as part of the provision of Communication, Navigation and Surveillance (CNS) services necessary for air navigation.
  • waste production.

Due to the awareness of the impact of its activities and the importance of protecting the planet and its resources, an Environmental Policy has been defined which formalises the ENAV Group's commitment in this area, as well as an Environmental Management System inspired by the principles of ISO 14001.

Climate engagement

The fight against climate change is the challenge of the century and the ENAV Group wants to make its contribution. ENAV's climate commitment stems from a deep-rooted awareness of the impact of its activities on climate and, more generally, of the contribution of civil aviation as a whole to the phenomenon of climate change.

With this in mind, ENAV has mapped out the two routes towards which to direct its climate commitment:

  • Contributing to the decarbonisation of the aviation sector
  • Reducing the carbon footprint of the ENAV Group's activities

Commitment to the decarbonisation of the aviation sector

ENAV is a key player in the international air traffic management system: it plays a key role in the initiatives aimed at the realisation of the Single European Sky promoted by the European Commission, through EASA (European Union Aviation Safety Agency) and EUROCONTROL, an intergovernmental organisation that supports the development of an efficient air traffic control system at European level.

ENAV is constantly engaged in the complex of activities aimed at modernising and optimising the infrastructure and network of ATS (Air Traffic Services), maintaining the safety levels of air navigation and contributing to the objective of progressive decarbonisation of the air transport sector.

The performance targets assigned at European level to ANSPs (Air Navigation Service Providers) require them to ensure the safe, timely and environmentally friendly movement of aircraft in their airspace at all stages of flight.

All actions planned and implemented in this area are catalogued and monitored, periodically, in the Flight Efficiency Plan (FEP). In the annual update of the FEP, all of the implementations of Operational Efficiency measures carried out by the Parent Company in the reporting period and in the various business segments are reported and assessed.

Flight Efficiency Plan

The Flight Efficiency Plan (FEP) is a multi-year action plan that is part of the European Single European Sky programme. Its aim is to create an airspace structure geared towards route network optimisation. The objective of the FEP is to contribute to the introduction of a state-of-the-art navigation system in Italian airspace, which can enable the reduction of energy consumption needed for flying and enable a decrease in customer operating costs.

Main benefits:

  • increasingly efficient flight profiles
  • direct routes with positive effects on consumption, emissions and costs
  • reduction of flight times resulting in lower operating costs
  • maintaining safety levels unaltered

Free Route Airspace Italy

The Free Route Airspace Italy (FRAIT) is a revolutionary project implemented by ENAV in 2016, as the first ANSP in Europe, which allows aircraft overflying at an altitude in excess of 9,000 metres to cross Italian airspace following a direct route that is free from the conventional route network. This design reduces fuel consumption and improves the energy profile of the flight, while maintaining safety levels.

Airport Collaborative Decision Making

Airport Collaborative Decision Making (A-CDM) is an operational procedure implemented at major Italian airports thanks to a cooperation between ENAV, the Airport Operators and EUROCONTROL's Network Manager Operation Centre (NMOC).

The objective of the procedure is to increase the efficiency and resilience of airport operations by optimising the use of resources through a continuous exchange of information.

Through the technology platform supporting the A-CDM, information on departing and arriving flights is exchanged between all Stakeholders involved. Based on the information received from the airlines, the platform is able to calculate the appropriate start time for all flights, in order to ensure the fastest taxi route and avoid waiting before departure.

Arrival Management

The Arrival Management (AMAN) system optimises the arrival sequence of aircraft in heavy traffic conditions. This system tells the controller the optimal sequence for separating aircraft and allows the arrival interval to be reduced, enabling a reduction in fuel and emissions generated by airlines, as well as a limitation of flight delays, which also benefits passengers.

During 2022, AMAN was implemented on Rome Fiumicino (at the Rome ACC where, among other things, approaches to Rome's airports are handled) and it is planned to implement this innovation also on Milan Malpensa (at the Milan ACC) in 2023.

FOCUS

Several sector studies have highlighted the need for a joint effort by all actors in the civil aviation sector to achieve a progressive reduction of the emissions generated and achieve carbon neutrality of aviation by 2050.

The commitment to decarbonisation of the Group's activities15

Alongside the broader objective of contributing to the progressive decarbonisation of air transport, the ENAV Group is committed to reducing the carbon footprint of its activities and has defined two main objectives in this area:

  • Carbon Neutrality 2022
  • SBTi targets to 2030

Carbon Neutrality 2022

The achievement of Carbon Neutrality represents an important - albeit intermediate - milestone in the ENAV Group's path towards a progressive reduction of its carbon footprint.

In 2022, through the projects and initiatives described below, ENAV achieved a reduction of approximately 75% in Scope 1 and Scope 2 emissions compared to the previous year. The currently non-reducible share of emissions will be offset, following the approval of this document, through carbon credits related to two environmental protection projects.

FOCUS

Renewable energy hydro India, a project to build a 300 MW flowing water hydroelectric power plant, whose main objective is to supply renewable energy to local communities in Kuppa, Kinnaur District Himachal Pradesh, India.

Efficiency improved cookstoves, a project developed in the city of Maputo in Mozambique (Chamanculo C and Xipamamine districts), whose main objective is the replacement of the traditional, highly polluting stoves used by about 1,800 households that will benefit from this project.

Science Based Goals to 2030 (SBTi)

The ENAV Group has defined climate targets for 2030 in which, parallel to the reduction of at least 70% of Scope 1 and Scope 2 emissions, a reduction of at least 13.5% of Scope 3 emissions in the categories "Capital goods", "Fuel and Energy-related activities" and "Employee Commuting" will be achieved16 .

These emission reduction targets have been validated by the Science Based Target initiative (SBTi), the initiative born out of a partnership between CDP (formerly the Carbon Disclosure Project), the UN Global Compact, WRI (World Resources Institute) and WWF in order to guide the private sector to climate action through science-based emission reduction targets.

The objectives validated by SBTi define the commitments of those companies that are in line with the level of decarbonisation necessary to contain the increase in global temperature below 1.5°C compared to preindustrial temperatures. For details of the Scope 3 emissions included in the ENAV Group's scope of operations, see Annex 1.

15 In compliance with the European common enforcement priorities for 2022 annual financial reports, issued by ESMA on 28 October 2022.

16 In 2019, the baseline year for the emission reduction targets validated by SBTi, these categories accounted for about 68% of total Scope 3 emissions.

GROUP CARBON FOOTPRINT

SCOPE
1
Direct
e missions
Emissions from sources owned by ENAV
Car and air fleet
Heating gas
Diesel generators
Refrigerant gases
SCOPE 2
Indirect energy
e missions
Indirect emissions related to electricity purchased from the grid
+
District heating
SCOPE 3
Indirect emissions
from the production
supply chain
Indirect emissions due to the company business
Capital goods, purchased products and services;
Indirect energy emissions upstream of consumption;
employee commuting; instrumental assets;
waste produced; business travel.

The commitment to reducing the carbon footprint of the ENAV Group's activities is structured as follows:

  • Electricity purchase via Guarantee of Origin (GO)
  • Interventions aimed at the energy efficiency of the ENAV Group's assets
  • Progressive increase in the share of self-produced energy from renewable sources
  • Replacement of the Company car fleet with electric-hybrid-plug-in vehicles
  • Development of energy research and innovation projects
Intervention Description
Purchasing
electricity via GO
All electricity purchased by the ENAV Group comes from institutional suppliers and is
certified from renewable sources with Guarantee of Origin (GO)
Energy efficiency of
assets

3 installations of LED systems with command and control domotics

6 ongoing modernisation of air conditioning systems

12 retrofitting of air-conditioning systems by 2025
Increasing self
produced energy
from renewable
sources

Trigeneration plant being commissioned at ACC in Rome

Planned geothermal plant at the new ACC in Milan

2 photovoltaic systems soon to be activated

10 photovoltaic plants under construction

7 photovoltaic systems in the planning stage

18 additional photovoltaic systems installed by 2025
Electric mobility
45% of the Company car fleet "electrified" in 2022

22 charging stations for electric cars installed in 2022

13 additional ENAV sites equipped with charging stations by 2024
Research and
innovation projects

Experimental design of 3 wind power plants

Future installation of a hydrogen-powered fuel cell system (Blue)

Presentation of a research project for the realisation of a plant for the production
of Green hydrogen from photovoltaic systems

Experimental project to replace conventional diesel fuel for powering GEIA
plants17 with HVO (Hydrotreated Vegetable Oil) fuel

In addition, the following is provided for in all investment projects, related to new implementations and adaptations of existing systems and facilities:

  • LED lighting systems
  • new fire protection and air conditioning systems using gas in accordance with the latest regulations.

17 Automatically activating generators to ensure the supply of electricity in the event of a blackout.

  • specific control units for air conditioning systems that improve management and maintenance, providing ideal temperature conditions for personnel and equipment, resulting in reduced energy consumption.
  • where possible, infrastructures equipped with "thermal jackets" and appropriate fixtures in order to improve thermal insulation and allow for an increase in energy class.

During 2022, the ENAV Group carried out an assessment to identify aspects for improvement and the main opportunities in the area of energy source management. The results of this evaluation, which will be further investigated in the near future, highlighted the following opportunities for ENAV:

  • construction of additional photovoltaic plants for self-production of electricity
  • conclusion of PPAs (Power Purchase Agreements)
  • participation in Renewable Energy Communities (both as "prosumer" and "consumer")
  • further impetus to the use of interior and exterior LED lighting
  • installation of Building Energy Management System (BEMS) for HVAC consumption management
  • installation of anti-solar thermal films
  • implementation of Uninterruptible Power Supply (modernisation of UPS devices).

Finally, in compliance with Legislative Decree 102/2014, in the course of 2023, the third energy diagnosis will be activated on 17 ENAV sites according to the clustering provided by ENEA. These sites were selected from the 30 most energy-intensive ones where ENAV is installing an energy management and monitoring system compliant with UNI ISO 50001 standards, which allows the analytical measurement of possible energy weaknesses in order to remedy them and turn them into future opportunities.

ENAV Group's Scope 1 emissions are generated by:

  • fuel consumption for air conditioning of ENAV offices and facilities
  • fuel consumption to power the car and aircraft fleet18
  • fuel consumption for emergency power supply of operational facilities
  • leaks associated with the use of refrigerant gases.

During 2022, Scope 1 emissions decreased slightly (-10%) compared to 2021.

As required by the GRI Sustainability Reporting Standard, the ENAV Group has calculated Scope 2 emissions according to the following two methodologies:

  • Location-based method, based on average emission factors for power generation on a regional, subregional or national basis;
  • Market-based method, based on the CO2 emissions generated by the electricity suppliers from which the organisation procures or on factors relating to the reference market.

18 ENAV has 4 Piaggio Aero P180 Avanti II aircraft at its disposal for the provision of the Flight Inspection service, aimed at ensuring maximum reliability of air navigation aid systems and enabling aircraft to operate safely and on time.

The graph below represents the total Scope 1 and Scope 2 emissions calculated according to the two methodologies described above.

In 2019, the ENAV Group started reporting on Scope 3 emissions, i.e. those generated upstream and downstream in the value chain. At present, the reporting of these emissions is in the following categories:

    1. Capital Goods, included in the reduction targets approved by SBTi.
    1. Fuel and Energy-related Activities, included in the reduction targets approved by SBTi.
    1. Employee Commuting, included in the reduction targets approved by SBTi.
    1. Purchased Goods and Services.
    1. Business Travel.
    1. Upstream Transportation and Distribution.
    1. Waste Generated in Operations.

In order to achieve a reduction in emissions generated along the value chain, the ENAV Group is evaluating the implementation of specific corporate projects and initiatives that will mainly be related to the following aspects:

  • further boost to energy efficiency measures.
  • where possible, increasing supplier involvement and further reviewing green procurement policies.
  • green mobility plans dedicated to ENAV Group people, including 'agile working' solutions to be progressively extended to an increasing portion of the corporate population.

As also recalled by the Environmental Policy, the ENAV Group is sensitive to the issue of biodiversity protection and, in this sense, has launched a number of initiatives, including with a view to raising awareness among internal and external Stakeholders.

FOCUS - URBAN BEEKEEPING

Bees play a fundamental role for our planet, as they ensure the presence of different plant species and are therefore a key element in the protection of biodiversity. Furthermore, a lesser-known aspect in which the contribution of this extraordinary pollinator insect is crucial is environmental biomonitoring.

In fact, bees are so-called "bio-indicator" insects as they are particularly sensitive to changing environmental conditions. In this sense, the analysis of their health status and behaviour can provide important information about their environment. For these reasons, in 2022 the ENAV Group decided to invest in an urban beekeeping project at the ENAV Training Centre in Forlì. As part of this project, three beehives were installed and currently "house" around 180,000 bees.

In the period from May to July 2022, beekeepers from apicolturaurbana.it carried out an initial biomonitoring of the health conditions and behaviour of the bees in the 3 hives installed at the ENAV Training Centre. They found an excellent state of health of the insects and a decidedly healthy environment.

FOCUS - REDUCING PLASTIC FOOTPRINT

Environmental pollution caused by the consumption of plastics and their dispersion and accumulation into the environment is causing problems to the habitat of flora and fauna. Inevitably, the consequences of this form of pollution also affect our health.

With a view to raising awareness in the ENAV ecosystem on this issue, a Company project aimed at eliminating plastic in our premises was launched in 2019. As part of this initiative, over the past two years water dispensers have been installed and a contract for the supply of water with containers other than disposable ones has been activated. In addition, the replacement of plastic material in vending machines throughout the country was ordered.

In the course of 2022, all contractual agreements for Company canteens throughout the country were remodelled to be "plastic free".

This, together with the actions already implemented in previous years, allowed a reduction of approximately 7.8 t of single-use plastics in 2022, compared to a reduction target of 1.5 t. This target represented the last step in the reduction of single-use plastics consumption, which was estimated at 14.2 t in 2019.

Reduction of electromagnetic emissions

The provision of Communication, Navigation and Surveillance services by ENAV is ensured by systems that generate electromagnetic fields of different magnitudes. In particular, radar, radio-assistance and radiocommunication systems installed at airport sites (45) and remote sites (about 100) distributed throughout the country are used. Compliance with the prescribed emission limits for non-ionising radiation is ensured by conducting appropriate electromagnetic impact assessments during both the design and installation phases.

Indeed, the Group's Environmental Policy establishes the principle of ensuring compliance with the emission limits envisaged for non-ionizing radiation through the conduct of appropriate electromagnetic impact assessments. ENAV guarantees the achievement of this objective, both in the design phase and in the installation phase, through the assessment of the electromagnetic field values of new systems.

ENAV's commitment is not only to ensure compliance with the prescribed limits but also to try to reduce electromagnetic emissions compatibly with the quality and continuity of the services provided. With this in mind, as part of the plan to decommission the NDB (Non Directional Beacon) radio beacons, a further 8 NDBs were switched off in 2022, making it possible to achieve the intermediate target of reducing the electromagnetic emissions generated by these facilities set out in the 2021-2024 Sustainability Plan for 2022.

The NDB radio systems decommissioning plan involves a rationalisation of these facilities that is functional to ENAV's PBN (Performance-Based Navigation) Transition Plan required by Regulation (EU) 2018/1048, whose main Stakeholders involved are ENAC, the European Commission and EUROCONTROL (European Network Manager).

The gradual phasing out of the radio systems is leading to a reduction not only in the electromagnetic impact generated but also in the consumption for the routine and extraordinary maintenance of these systems, including the costs and fuel consumption of the vehicles used to reach the remote sites where these systems were located.

Waste management

On the issue of waste management, the ENAV Group assumes and defines as strategic the commitment to govern waste disposal activities through the traceability of the entire process with the aim of giving the maximum possible implementation to the hierarchical criterion of prevention, reuse, recycling, recovery and disposal, in full compliance with current regulations.

The management of this matter and its impacts takes place through:

  • the adoption, in line with the commitment expressed in the ENAV Group's Environmental Policy, of an Environmental Management System that meets the requirements of the ISO 14001 standard;
  • prevention of the possibility of non-compliance with regulatory requirements, through the use of a computerised system for managing waste registers and transport forms;
  • the progressive increase in the percentage of special waste sent for recovery out of the total waste produced, through the adoption of appropriate reward criteria for the awarding of waste transport and disposal/recovery services;
  • the adoption of various initiatives regarding the management of waste produced by office activities, such as the elimination of plastic containers from beverage dispensing machines used by ENAV Group Companies.

The effectiveness of the actions undertaken is monitored through internal audits and the monitoring of indicators.

Waste created by ENAV Group enterprises is collected, transported, and subjected to recovery/disposal operations by third-party organisations with the relevant qualifications and authorisations, with which the ENAV Group has special contractual connections.

The share of municipal waste is handled through the companies in charge of cleaning services by qualified third-party companies, as mentioned above, or by the public collection service.

Verification that the companies in charge of waste management services, as well as the companies in charge of cleaning services, operate in accordance with both contractual and legislative obligations is carried out by the Contract Managers in charge and the Managers of the sites and territorial offices concerned, in application of the ENAV Group's Environmental Management System procedures.

The "Prometeo Rifiuti" software application is used to collect and monitor data relating to special waste, in which data are entered on all waste loading and unloading operations carried out at all operational sites and offices of ENAV Group Companies located throughout the country.

Technological innovation and digitalisation

In ENAV, innovation, technological development and professional growth are the drivers through which all assets are best exploited.

The development of the operating model, the digitalisation of the Company, the development of new abilities and new business lines, such as drones and new services for the foreign market, create the conditions for relaunching the Group towards increasingly ambitious results compared to those achieved thus far.

The most important projects related to environmental issues (such as the aforementioned Free Route, A-CDM, AMAN and others), are the result of investments that have led ENAV to be an international leader and have been dedicated to:

INNOVATION OF INFRASTRUCTURES

Participation in experimental programmes for the implementation of flight procedures based on Satellite Navigation systems, programmes that have enabled free-route navigation and which, together with new techniques for the design of operating procedures (PBN), are already enabling ENAV to decommission terrestrial navigation infrastructure.

DIGITALISATION OF COMMUNICATION

Replacement of printed communications in the towers with information displayed in real time on the radar screen at your station (EFS - Electronic Flight Strips). In addition, with the new Datalink system, digital and traditional communication – ground-air-ground radio – are integrated, reducing the risk of misunderstandings in radio communication between controllers and pilots. ENAV is also collaborating in the evolution of the datalink through the development activities of the IRIS satellite constellation that will transmit datalink messages via satellite.

INTEROPERABILITY OF THE PLATFORM

The management of air traffic needs to be fluid and efficient, also on a supranational level. For this reason, different entities (service providers, airlines, airports, military) must be able to coordinate their data in real time in order to easily cooperate for flight management. COFLIGHT: a system developed with the French DSNA that makes it possible to further improve the system for the automation of operations.

Thanks to the innovation and constant professionalisation of resources, the ENAV Group, the first among European Service Providers, has revolutionised the methods for crossing Italy's air space. In addition to the activities already described (in particular the aforementioned Free Route), the ENAV Group is working on other innovative projects that will revolutionise the sector, such as the Virtual Centre concept for the delegation of ATS services between ATC centres and for the management of contingency situations, the innovative Conflict Detection & Resolution tool based on the use of on-board data and artificial intelligencebased logics, and systems for the dynamic configuration of airspace according to traffic demand. Each of these solutions is characterised by an important impact on ATM performance from a green perspective.

REMOTE TOWER

Air traffic at low density airports will be managed by remote control towers that will be concentrated in two control centres at a national level. In this way, the airports will be able to operate 24/7, with a lower use of resources and energy, opening up to the needs of the airlines for flexibility, thereby making Italy's national economic system more attractive. In June 2022, the first Remote Tower in Italy went into operation at Brindisi Airport. In addition, within the SESAR programme, research activities were conducted on Remote Tower Centre and Multiple Remote Tower Operations.

ARRIVAL MANAGEMENT SYSTEM

This system will indicate to the controller the optimum sequence calculated for separating incoming aircraft at congested airports, thus enabling an important recovery of consumption and a further reduction in delays. The first operational implementation in Italy took place in December 2022 at the ACC in Rome.

SATELLITE SURVEILLANCE – AIREON

AIREON, of which ENAV is a shareholder, provides satellite surveillance services that make it possible for airlines to optimise their flight profiles in areas that are not covered by traditional surveillance, enabling an optimisation of consumptions.

CONSOLIDATION OF APPROACHES IN AREA CONTROL CENTRES

The consolidation of the approaches into Area Control Centres will optimise the approach procedures.

From the point of view of technologies, the ENAV Group is concentrating its efforts on the use of the most advanced techniques for the analysis and management of flight data, to examine the possible passage from the level of predictive capacity to the higher prescriptive one. An example of this is the CORA project (Conflict Resolution Advisory) project, which is one of the cutting-edge functionalities of en route air traffic control systems. With the present-day capability to report possible conflicts in the trajectories indicated by the aircraft, this system will add the level of "suggestion" with respect to the better and more efficient trajectory to follow in order to avoid conflict.

Future goals

    1. Monitoring and promoting digitisation and technological evolution with particular reference to the automation of CNS/ATM infrastructures.
    1. Ensuring the evolution process of Communication, Navigation and Surveillance infrastructures, and synchronised deployment of ATM infrastructures, in line with European infrastructure planning and EU regulations.
    1. Ensuring that the deciding factor in the selection of research and development activities in Europe is increasingly oriented towards sustainability objectives.

As part of the management of technological innovation and digitalisation, the ENAV Group participates in the European research and development programme SESAR, an initiative launched by the European Commission to provide the Single European Sky regulatory framework with innovative technological elements that enable the creation of a new air traffic management system that is modern, interoperable, sustainable, resilient, efficient and capable of ensuring the development of air transport on a safe, environmentally friendly and less fragmented basis in airspace management.

In particular, in 2022 ENAV conducted a series of experiments on innovative operational concepts and supporting technologies aimed at improving the performance of the ATM system. In addition, it participated in European calls for tender for the new SESAR 3 programme (2023-2031), related to the objectives of the European Aviation Green Deal and the digital transition, responding with project proposals for exploratory and industrial research, as well as launching 2 new demonstration projects.

Also in the context of managing the theme of technological innovation, the ENAV Group is engaged in planning and launching the rationalisation of the less efficient components of the CNS (Communication, Navigation and Surveillance) infrastructures, thanks to the use of innovative distributed and satellite architectures and new operating procedures.

Finally, ENAV constantly oversees technical round tables aimed at promoting the standardisation of new sustainable and environmentally friendly technologies.

In this context, the main commitments undertaken by the ENAV Group can be summarised as follows:

  • Research and validation of new technologies (including satellite technologies) enabling innovative CNS/ATM services, planning their deployment through research projects to reach the appropriate maturity levels for operational commissioning.
  • Planning demonstration trials whose purpose is to accompany new technologies towards industrialisation and deployment.
  • Undertaking ongoing collaborative relationships with key industry Stakeholders, universities and national and European research centres to identify low-impact opportunities arising from the use of new technologies such as artificial intelligence or machine learning algorithms applied to the CNS/ATM context.
  • Pursuing the directions provided in the European Airspace Architecture Study and ATM Master Plan regarding the evolution of the CNS infrastructure and ATM services with a focus on improving the Key Performance Areas of Capacity, Environment, Cost and Safety.
  • Planning investments based on operational priorities, selecting the most sustainable technologies from the portfolio of executed projects.

In order to monitor the effectiveness of its commitment to technological innovation, the ENAV Group has implemented the following tools:

  • Processes of periodic technical and financial reporting to the financing bodies.
  • Monthly internal structure reporting.
  • Definition and monitoring of critical project milestones and the investment plan.
  • Structuring meetings as a time to share the technical progress of actions, discussing activities and identifying areas for improvement.

In this context, dialogue with industry Stakeholders plays a central role. In fact, international round tables involves the participation of strategic Stakeholders in the decision-making chain to define the European roadmap for the evolution of CNS/ATM infrastructures and services.

In addition, participation in strategic organisations for the implementation of the new European ATM/CNS infrastructure such as the new SESAR Deployment and Infrastructure Partnership (SDIP), SESAR 3JU and the A6 alliance enables the prioritisation and allocation proposals of European funds for the launch of projects of interest, while ensuring that they are driven by real operational needs.

In the near future, the ENAV Group plans to manage the issue of technological innovation:

  • monitoring and promoting digitisation and technological evolution with particular reference to the automation of CNS/ATM infrastructures.
  • ensuring the evolution process of Communication, Navigation and Surveillance infrastructures, and synchronised deployment of ATM infrastructures, in line with European infrastructure planning and EU regulations.
  • ensuring that the deciding factor in the selection of research and development activities in Europe is increasingly oriented towards sustainability objectives.

INNOVATION, DIGITAL AND SUSTAINABILITY IN THE ENAV GROUP

The ENAV Group has embarked on a path of integration of innovation and digital transformation to support sustainable development.

Innovation, digital and sustainability are intrinsically linked and necessary elements of the Business Plan. This approach implies the realisation of technological innovation projects in line with sustainability issues, also investigating new potentials in the commercial market by proposing prototype and demonstration solutions, feasibility studies and pilot projects needed in the embryonic stages of evaluation and production of new services.

Innovation and Sustainability activities stimulate, accelerate, and accompany the implementation of projects through the formation of intra-Company working groups and external Stakeholders, selecting technological excellence and talent. All activities are united by the intention to support the ENAV Group's evolution towards ESG objectives and are differentiated into macro-areas with different impact focus and timeframe:

  • ENAV Digital: promotes the Group's digital transformation by integrating and maintaining harmony between the Company and the continuous evolution of society, the labour market, changes in people, culture, expectations and aspirations of the individuals who make up the ENAV employee community.
  • Data-driven Company: promotes the culture and usability of data in the Company to support strategic choices, direct activities and operations by making decisions at all levels based on objective, up-to-date and transparent information;
  • Disruptive Innovation: represents the group of initiatives aimed at generating opportunities in new markets through continuous testing of emerging technologies, resulting in the development of innovative services.
  • ATM Virtualisation: this chain represents the next step in terms of technological evolution in ATM, with positive impacts in terms of safety and flexibility in service delivery, also constituting a key element to make ENAV an ATM Data Service Provider to other Air Navigation Service Providers.

The objectives it concretely pursues, in line with what has already been stated in the 2022 Business Plan, can be summarised as follows:

  • Pursue the Digital Innovation strategy and governance fully integrated to sustainability; hence, to the development of new sustainable (low impact) digital tools that in turn have a direct and indirect positive impact on the ESG sustainability of our industry and circular economy context.
  • Realise "ENAV Digital" by fostering the evolution of digital systems to support the paperless Company, a sustainable supply chain, efficiency and quality of work also in the interactions between the ENAV employee community and between them and external Stakeholders through process innovation, and the introduction of new technologies (cloud and intelligent automation).
  • Support the "Data-driven Company" approach and paradigm through a data strategy, data supply chain governance models, digital technologies (e.g., Big Data, Data Lake, AI, IoT, predictive systems) and change management (e.g., upskilling, reskilling and certification of employees on technologies, roles and new agile working methodologies).
  • Integrate the open innovation paradigm in the Company, capitalise on the benefits of open-source software, new business models, partnerships, and an industrial intellectual property protection strategy in order to improve business results.
  • Present the ENAV Group to the market and the Italian economy as excellence in technology, sustainability, and a working environment capable of growing its resources, attracting, and continuously motivating young digital talent and innovators. The integration of innovation, digital and sustainability in ENAV is proposed as an incubator of sustainable and innovative solutions on digital issues, in order to anticipate the technological evolution of the market, explore and generate partnerships and opportunities for new commercial services.

ENAV Group investments

ENAV invests heavily to ensure that assets supporting air traffic management services in Italy are consistent with the objectives of technical, financial and performance requirements, and that they comply with quality and performance standards established at national and international levels.

In line with technological changes that are occurring internationally in the sector, ENAV has crafted a technical operations development plan with the aim of remaining competitive on an international stage and maintaining its leadership in technological innovation, in keeping with the Single European Sky requirements.

The Business Plan envisages investment in innovative technological platforms and systems for air traffic control for the 2020-2024 period in order to maintain high levels of performance and to ensure maximum safety.

The international situation ensuing from the pandemic has conditioned the plan, diluting its effects for 2020 and 2021, yet maintaining important objectives for some initiatives, including:

  • The consolidation of approaches in Area Control Centres (ACCs), a project that entails a shift of the management of approach procedures in several airports towards the competent ACCs, thus obtaining an optimisation of resources.
  • The new 4Flight system, a new-generation operational platform that will be implemented following a new approach to development and maintenance.
  • The upgrading of the airport weather observation systems to align them with the new regulations and to gradually implement the automation of producing weather reports.
  • The building of a Technical Operation Centre (TOC) to support changes to ENAV's maintenance processes, which goes beyond the current peripheral maintenance model in favour of a new centralised model that fully exploits all the new virtualisation, remotisation and communication technologies by fully integrating information, resources, and processes.
  • The realisation of Remote Towers, which make it possible to manage the traffic of a certain airport from a remote management centre.
  • Implementation of new management systems for the Airport Towers of strategic airports.
  • Implementation on the current air traffic management system (SATCAS) of interventions to improve performance and safety.
  • the new E-NET 2 network with multiprotocol label switching technology, which is capable of making data transmissions faster and more secure. This infrastructure forms part of the foundation for the establishment of remote-control towers.

On the basis of the development strategies, having as their primary objective the support of air traffic management services in the national territory, in 2022 the ENAV Group invested overall approximately €88 million through implementation and maintenance projects for operational technological infrastructures, evolution of the ATM technology platform with new operational concepts, infrastructure, equipment and management information systems, with total investments that amount to approximately €97.8 million.

Actions related to the provision of air navigation services

Starting from 2012, the results of the actions reported in the Flight Efficiency Plan (FEP) are emphasised in the national plan for the reduction of carbon dioxide emissions - "Italy's Action Plan on CO2 Emissions Reduction" - that Italy is required to implement as part of the broader programme for combating climate change adopted, in the aviation sector, by ECAC/ICAO.

In 2020, the extraordinary situation caused by the health emergency due to the COVID-19 pandemic had resulted in an absolutely significant global contraction of air connections, which had also characterised 2021, albeit with a less pronounced incidence from the second half of the year.

Since the beginning of 2022, particularly April, in continuity with the trend recorded in 2021 and in parallel with the other countries in the ECAC area, the upturn in traffic has been noticeable, both in overflights and in air connections departing/arriving from domestic airports, with numbers stabilising at over 90% compared to 2019 values.

In the middle months of the summer season, especially at domestic airports serving tourist destinations, traffic values were even higher than the pre-COVID period; similarly, the upswing in planning related to the Christmas period reached values similar to those recorded during the same period in 2019.

The balance for 2022 shows, in terms of en route service units, a rise of 63.2% compared to 2021 and, in terms of assisted flights, fall of 9.1% compared to pre-pandemic volumes.

In order to meet the increased demand for ATC capacity effectively and to optimise the management of air traffic flows, against the backdrop of the planning of so-called Airspace Users, in the ATC EnRoute sectors and for flights taking off from or landing at domestic airports, in the course of 2022, the gradual reactivation of constraints on the use of the network that had been suspended in 2020 and 2021 was carried out.

In continuity with what has been implemented in previous years and in addition to what has already been achieved with the implementation of the Free Route Airspace Italy (FRAIT) Project19, during 2022 - thanks to the coordination with the Air Force (AM) - the Parent Company maximised "Airspace Availability", continued the updating and synchronisation activities of the ATS Network below FRAIT and in the Terminal areas, but also carried out interventions that allowed for improvements in performance related to airport movement area operations.

In particular, with regard to the FRAIT Airspace alone, it should be noted that about 43% of the assisted air traffic was able to benefit from a reduction in the total distance, from the departure airport to the destination airport (gate-to-gate), resulting in an overall reduction of about 16.3 million planned kilometres (equal to almost 32 km per aircraft), with a consequent saving of fuel needed for 'cruising' flight operations (En Route) estimated at about 65.3 million kg in total and CO2 emissions of about 210 million kg.

At the same time as the reduction in the total distance of the trajectory flown in FRAIT airspace, and taking into account, above all, the increase in the cost of fuel, but also the changed connection scenario that has seen the creation of commercial flights based on new City Pairs and the consequent updating of the planning of the connection trajectories of new destinations, a factor to highlight is the significant increase - compared to what was recorded in 2019 - of the occupancy value of national airspace, most used by Airspace Users.

Occupancy values increased, on average by about 2 minutes per assisted flight.

19 A Project that consists of greater freedom in planning of trajectories in airspace above 30,500 ft (approx. 9,000 m) and allows airlines to choose the shortest flight path.

The attractiveness of the use of airspace was supported by the combination of the excellent performance in terms of capacity and predictability, but also by the numerous Flight Efficiency measures implemented to make flight paths more efficient and, consequently, to contain and optimise fuel consumption and the associated CO2 emissions into the atmosphere.

Evidence of the added value generated by the various measures taken together can be found in the reduction of the Total Route Length planned by airspace users on the City Pair and the concomitant preference to plan their flight in Italian airspace rather than in neighbouring airspaces. If in the FRAIT Airspace the constraints that characterised the previous Network had already been removed, allowing Airspace Users to plan and fly according to direct trajectories (from a defined point of entry into national airspace to a point of exit from airspace), continuing on this approach, additional interventions were carried out in 2022 to allow further harmonisation of flight profiles involving Military Areas.

In close cooperation with the Air Force, and in a shared application of the Flexible Use of Airspace (FUA) concept, these interventions resulted in a further reduction of planned/flighted distances with results that can be estimated at a reduction of about 2.17 million kg of fuel, with a consequent reduction of CO2 emissions into the atmosphere estimated at about 6.83 million kg.

Also in 2022, with reference to the Terminal areas, the Parent Company continued to implement two multiyear programs:

  • i) the plan for the transition to Performance Based Navigation (PBN), with the publication of satellitebased instrument flight procedures and the associated phasing out of outdated, ground-based, radio systems that are more polluting in terms of radio emissions, such as Non-Directional Beacons (NDB) and/or Locators.
  • ii) the transfer of responsibility for the provision of approach control services in area control centres (which, in 2022, involved the transfer of the approach control service of the Naples CTR to Rome ACC).

The two programmes make it possible to optimise the ATS network in the Terminal with a further balance between Flight Efficiency and Capacity and Predictability performance, with expected overall reductions in fuel consumption and CO2 emissions estimated at around 12.0 million kg of fuel and 37.8 million kg of lower CO2 emissions by 2022.

The ENAV Performance Based Navigation Plan

The Instrumental Flight Procedures (IFP) of the Performance Based Navigation (PBN) type are a priority for ENAV since, on the one hand, they make possible more efficient design and utilisation in the terminal area, enabling the rationalisation of airspace use and, on the other, they reduce environmental pollution and energy and maintenance costs connected to conventional ground navigation infrastructures.

The design of PBN-type IFPs makes it possible to create a terminal ATS network that is more functional to flight operations and flight control and facilitates enhancement of the balance between performance levels of flight efficiency, capacity and predictability, with the consequent possibility of optimising airspace user planning and potential improvements in planning/fuel consumption and related CO2 emissions.

In 2020, by way of application of EU regulation 2018/1048 (PBN IR), following the high-level principles developed by the Italian government and in coordination with the Stakeholders involved, ENAV developed its own transition plan, from a conventional ground-based navigation network to the innovative PBN network (ENAV's PBN Transition Plan) which, as an improvement, and in conjunction with Italy's PBN Implementation Plan (adopted jointly with ENAC in 2012 in implementing ICAO Assembly Resolution A37-11), constitute an element in support of the National Airspace Strategy and a useful way to achieve the objectives defined therein.

The first edition of ENAV's PBN Transition Plan focuses on the measures to be carried out in the short to medium term (2020-2024), such as the implementation of RNP-type instrument approach flight procedures and the gradual and incremental decommissioning of ground-based navigation infrastructures based on the now obsolete NDB (Non-Directional Beacon) radio assistance.

The plan encompasses a periodic update in order to consider the evolution of the Global Navigation Satellite System (GNSS), the performance level of the system itself, the rate of implementation of on-board avionics and the progress of programmes to rationalise conventional radio navigation aids (Navaids) (NDB and VOR).

Periodic monitoring of the interventions set out in ENAV's PBN Transition Plan, as well as those in Italy's PBN Implementation Plan, are included in ENAV's FEP.

The Development of Advanced Air Mobility

The future of sustainable mobility also passes through the development of Advanced Air Mobility and its urban component. This new dimension is bound to have a significant impact on the urban mobility sector of goods and people and its allied industries.

In accordance with the "National Plan for Advanced Air Mobility", prepared by ENAC, the Group and, in particular, the Parent Company are collaborating with government and private Stakeholders in defining the proposed regulatory framework that will enable the development of Advanced Air Mobility in Italy.

Following Memorandums of Understanding and Cooperation Agreements with ENAC and other Stakeholders in the sector, on the strength of the experience gained in the realisation of the ATS network, ENAV is proactively contributing to defining the development of a network of air connections between nodes of a future general mobility system (airports, stations, ports, interchange centres and nodes, logistics hubs, etc.) that can support the effective use of innovative electrically-powered aircraft (drones, but also electric vertical take-off and landing - eVTOLs), thus helping to create the conditions to replace or at least reduce the use of less environmentally friendly modes of transport.

Under the stimulus of ENAC and in synergy with the other players in the sector, the Group Companies are providing their technical and operational contribution to define:

    1. the regulatory framework, both national and supranational, necessary to develop the aerial operations of Unmanned Air Systems (UAS), with remote pilot and/or for automated/autonomous operations, to be conducted in VLOS20, EVLOS21 and BVLOS22, within the national U-Space.
    1. the criteria for the design, interference assessment and implementation of the network of connecting, arrival and departure routes between advanced mobility nodes (airports/heliports and vertiports and the "regulatory sandboxes").
    1. the methods for managing interference between Air Traffic Management (ATM) and Unmanned Traffic Management (UTM), in order to develop services for airspace users, from the logic of segregation to the logic of integration and dynamic reconfiguration of U-Space.
    1. of basic and supplementary services for the new aircraft and the conditions for certifying U-Space Service Providers (USSPs).

The development of new operating concepts, new infrastructures and networks, new services and air operations will increase the range of services available to citizens and businesses and will make it possible, albeit gradually, to develop a new segment of air transport that will make it possible to reduce and, in some cases, replace modes of air transport that produce harmful atmospheric emissions with innovative, electrically-powered and therefore environmentally friendly means.

To understand fully the potential behind Advanced Air Mobility applications, it is crucial to comprehend how important the drone segment is for the sustainable development of air traffic.

20 Visual Line of Sight (VLOS): operations conducted within a distance, both horizontal and vertical, such that the remote pilot is able to maintain continuous visual contact with the aircraft, without the aid of sight-enhancing instruments, allowing him/her direct control of the aircraft to manage flight, maintain separation and avoid collisions.

21 Extended Visual Line of Sight (EVLOS): operations conducted in areas whose dimensions exceed the limits of VLOS conditions and for which VLOS requirements are met by the use of alternative methods.

22 Beyond Visual Line of Sight (BVLOS): operations conducted at a distance that does not allow the remote pilot to remain in direct and constant visual contact with the aircraft, which does not allow flight management, maintaining separations and avoiding collisions.

These vehicles will be increasingly used for the transport and delivery of goods, emergency medical assistance, environmental monitoring, mapping of territory, precision agriculture, inspection of critical infrastructures, and much more still, and all will have to be managed in maximum safety conditions.

This is why - in partnership with Leonardo S.p.A. and Telespazio S.p.A. - D-Flight S.p.A. was created, the only platform in Italy, and one of the first in Europe, for the provision of services to remotely piloted aircraft and all other types of aircraft that fall under the category of Unmanned Aerial Vehicles (UAV).

The Group's new Company, D-Flight, pursues the development and provision of services for the low-altitude air traffic management of all types of aircraft in the unmanned aerial vehicle (UAV) category and all related activities.

With the development of the U-space platform, which enables the safe integration of drones into civil airspace, ENAV, through its subsidiary D-Flight, intends to make its indispensable contribution by guaranteeing the safety of flight operations.

U-Space is the air space below 150 metres, considered as the key element for the safe use of drones in every context and for all types of missions. U-space services evolve in parallel to the level of drone automation and guarantee advanced forms of interaction with the environment (including aircraft with and without a crew), through the exchange of information and digital data.

A continuously increasing number of drones are expected to be used (by 2050 it is expected that about 7.4 million drones will fly in the European skies) in a growing number of industrial and civil areas.

The objective of D-Flight is therefore to integrate and make these new needs coexist with traditional aircraft, while keeping the entire air space safe. Our Vision is a world in which drones are common objects that are fully accepted in the daily life of all citizens, which are safely used in urban environments and offer services that are increasingly efficient, innovative, economic and above all sustainable.

For these reasons, we are working with national authorities to accelerate the development and implementation of technologies, infrastructures and services able to make the autonomous flight of drones possible in any permitted operational scenario, with complete safety and efficiency. Therefore, D-Flight wants to actively contribute to the realisation of this vision by supplying enabling technologies that permit the progressive performance of the operations in increasingly complex and challenging operational scenarios.

The flight inspection service for safety in the sky

ENAV, in line with the objective of enabling air transport operators to fly in compliance with the highest levels of safety, through its own fleet of aircraft, carries out punctual control activities on the quality and accuracy of radio signals, both nationally and internationally, and validates flight instrument procedures for fixed-wing aircraft and helicopters, thus providing a guarantee of safe and efficient navigation.

The mission of the Flight Inspection and Validation service is to ensure the maximum reliability of air navigation aids and enable carriers to operate safely and efficiently.

The control activity is carried out by 13 pilots and 7 technicians on board through a fleet of 4 Piaggio Aero P180 Avanti II aircraft owned by ENAV. The crew is usually composed of 2 pilots and 1 FIO, averaging more than 1,300 flight hours per year. These specially equipped aircraft can perform in-flight checks without the need for ground-based apparatus, obtaining results in real time and at all times in observance of international regulations.

From 2023, the Flight Inspection and Validation service can count on a new mobile validation platform (RIFIS), developed by ENAV and dedicated to the validation of procedures used by helicopters.

The Flight Inspection and Validation facility is also active in the field of research. In fact, the fleet's aircraft are used as a technologically advanced 'laboratory' thanks to which it is possible to carry out tests for the experimentation and validation of new ATM projects.

2. Stakeholders

Stakeholder engagement

Stakeholders are fundamental in the process of value creation and are considered an integral part of the responsible and sustainable management of the business, so Stakeholder engagement is an essential process for the Company, and ENAV, over time, has strengthened it further through Stakeholder management.

In 2022, dialogue continued with the most representative Stakeholders, with a view to maintaining ongoing relations through a programmatic and proactive approach to managing their needs and expectations. The development of long-term relationships increases the trust of both internal and external Stakeholders and strengthens the Company's image and reputation.

In its relations with its Stakeholders ENAV pursues a five-step strategy:

Investor Relations and financial disclosure

ENAV has always placed a great deal of attention on its relations with investors, financial analysts and the financial community in general, establishing the Investor Relations unit in order to manage these relations in a continuous and effective way.

The opportunities for dialogue are many: conference calls, in-person and virtual meetings, financial an industry conferences, site visits and roadshows. In these events, the management team, typically the CEO (Chief Executive Officer) and/or the CFO (Chief Financial Officer), together with the head of Investor Relations, disclose to the financial community the main results for the period (quarterly, half-yearly, annual), business trends and strategy guidelines, and the team is available to answer any questions received from individual participants.

All the economic and financial information related to the Company, as well as the main share performance indicators and the analysts' opinions can be found in the Investor Relations section on ENAV's website.

A dedicated mailing list is also available to the financial community, which the Company uses to periodically communicate information concerning ENAV, as well as an e-mail address through which Investor Relations answers questions from investors or financial analysts in the event of new business activities or particular market trends.

In the period from January to December 2022, ENAV had more than 220 interactions with institutional investors, carried out partly in person and partly virtually due to the continuation of the pandemic emergency that mainly characterised the first half of 2022.

In addition to investor relations, ENAV maintains frequent contacts with financial analysts covering the stock (so-called "sell-side"). The 11 analysts who covered ENAV stock in 2022 come from major Italian and foreign brokerage firms, some of whom specialise in infrastructure firms, and periodically publish reports and updated analysis of ENAV's activities, performance and financial position. Of these eleven analysts, at the end of 2022 nine had a "BUY" rating on the ENAV stock and two a "HOLD" rating.

Finally, it is important to underline that during the year the interest of the main institutional investors in (ESG) issues and in the activities undertaken by ENAV on this front further increased. In order to ensure sustainability in the Company's long-term business, ENAV has included a specific section on sustainability in its institutional presentations to investors, with a view to increasing transparency on its activities, involving investors in its Stakeholder Management initiatives and participating in financial conferences and events on the theme Environmental, Social and Corporate Governance (ESG).

For 2023, ENAV aims to further expand opportunities for interaction and meeting with the financial community, exploiting occasions such as roadshows, financial conferences and conference calls, both faceto-face and virtual. In addition, during 2023 the Company aims to expand its investor base, focusing on:

  • investors located in geographic areas not reached during the listing process.
  • investors with a medium- to long-term investment perspective, with a focus on Sustainable and Responsible Investment (SRI) funds, expanding their disclosure on ESG issues.
  • specialised infrastructure funds.

ENAV share performance

ENAV has been listed since 26 July 2016 on the Mercato Telematico Azionario MTA (now EXM - Euronext Milan) managed by Borsa Italiana S.p.A. and is currently the only Air Navigation Service Provider (ANSP) to be listed on the capital market.

Since the listing date, ENAV's share price has increased by 20%, with a market capitalisation as at 31 December 2022 of approximately €2.14 billion.

During FY2022, the share price showed a slightly positive trend, starting with an opening of the year at €3.93 and closing the year at a price of €3.96 (an increase of about 1%).

The performance of ENAV shares during the year was influenced by exogenous factors mainly related to the outbreak of the conflict in Ukraine and the significant increase in interest rates and inflation.

The highest share price in 2022 was on 20 April, with a price of €4.70, while the lowest price was on 7 March, at €3.54.

Shareholding structure

At the end of 2022, ENAV's share capital amounted to €541,744,385 and remained unchanged compared to 2021.

The MEF (Italian Ministry of Economy and Finance) holds a 53.3% stake in ENAV while the remaining 46.7% is floated on the Italian stock exchange. Below is given the detail of ENAV's shareholding base resulting from shareholder identification conducted in November 2022, divided by type and geographical area.

Relations with industry organisations, institutions, and associations

ENAV's attention to the civil aviation community not only takes the form of the air traffic control services it offers, but also through collaboration and participation in activities.

In fact, ENAV operates in a highly regulated sector, with a predominantly international perspective due to the nature of the aviation industry, which has many elements of regulatory complexity.

The main organisations, institutions and sector associations with which ENAV collaborates:

National Bodies and Institutions
Text
· ENAC - National Civil Aviation Authority
· ANSV - National Flight Safety Agency
AM - Air Force
· MET - Ministry of Economy and Finance
· MIT - Ministry of Infrastructure and Transport
Text
European Commission
· EUROCONTROL - European Organisation for the Safety of
Air Navigation
· ICAO - International Civil Aviation Organisation
· CANSO - Civil Air Navigation Services Organisation
· EUROCAE - European Organisation for Civil Aviation
Equipment
· EASA - European Union Aviation Safety Agency
A6 Alliance
International Organisations and Institutions

Regarding the management of activities concerning relations with organisations, institutions and sector associations, ENAV has in place Procedures of the Company's Quality Management System (QMS), which define the processes, responsibilities and internal and external actors involved.

By way of example, the set of procedures relating to international regulations and the participation of ENAV personnel in the activities of international bodies should be noted. These procedures define the processes and methods for engaging internal resources and the national and international organisations and institutions that are entitled to issue and amend standards for ENAV (e.g., procedures for international participations and for consulting international regulations). Further initiatives are also in place, which identify areas of risk/opportunities that this sphere may create in the life of the Company by providing tools to monitor and influence the regulatory sphere as necessary, in accordance with the objectives set out in the Business Plan, by organising the lines of action, i.e. planning the activities and methods by which corporate/group objectives are identified, developed and pursued, supporting the implementation of concrete measures and the verification of the progress of activities (e.g. the International Regulatory Action Plan).

Main ongoing activities:

The relationship with entities, institutions and industry associations is one of the material issues for the Company, and in this sense the Company has identified the regulatory dimension related to it as one of the areas on which to focus in the Business Plan for the risks and opportunities it may create. To this end, the adoption of and compliance with the aforementioned procedures are essential to mitigate the potential negative impacts arising from relations with sector bodies, institutions and associations. In particular, being aware of the state of development of the international, community and national processes, defining the strategic areas and priority issues to be monitored for the achievement of corporate objectives, actively participating in the various international and national decision-making fora promoting ENAV's role, positioning and role, the activities carried out, the investments made as well as the skills acquired, which represent the success factors and the competitive advantage that characterises the ENAV Group, minimises the risk of negative impact of the activities. With this in mind, monitoring actions were implemented to identify critical activities and their progress index, as well as the identification of opportunities for ENAV, in relation to the planning set out in the Business Plan. Once critical issues and opportunities have been identified, action is taken in a synergetic manner, including coordination between external bodies, institutions and organisations and/or Organisational Structures of the Company responsible for the topic. The process involves, through Quality Management System and other initiatives, the identification of the risks/opportunities that international regulation and international strategic positioning may create for the Company and the verification of the progress of related activities (e.g. Action Plan International Regulation, Procedure for Monitoring Reporting). Priority regulatory areas are defined, the external and internal actors involved are identified and then the progress of activities is constantly monitored, through the periodic updating of the Action Plan itself, in cooperation with the Organisational Structures concerned. The effectiveness of what the Company has put in place can be defined on the basis of the alignment of regulatory and international planning developments with the Company's strategic lines and activities.

Future goals Deadline
Primary role of ENAV in Traffic Management for UAS - UTM 2023-2025
ENAV, together with its subsidiary D-Flight, and in cooperation with Italian authorities, plays a
driving role in this new sector, with enormous benefits on a social and economic level, both on
a European and international level. The recognition of a leadership role offers ENAV and the
Country System valid commercial opportunities for the supply of services, know-how and
infrastructure systems on the international market.
In addition, the subsidiary Techno Sky received the necessary authorisations from EASA for the
use of drones in the monitoring of certain technological systems, with considerable benefits in
environmental and economic terms.
ENAV's primary role in Higher Airspace Operations (HAO) and Space Traffic Management
(STM)
2023-2025
The aim of the STM is to ensure the safe development of airspace operations at higher
altitudes than those currently used by traditional aviation, reducing the risk of collisions and
interference, in cooperation with the ATM, promoting the long-term sustainability of space
activities.
From that point of view, ENAV is playing an active role in important initiatives, in synergy with
the national regulator ENAC and with other national and international actors. One example is
the ECHO project (European Concept of Operations for Higher Airspace Operations), which
aims to develop an operating concept and solutions for the development of this new type of
traffic, analysing in particular demand, aircraft types and operational requirements.
Intercept market opportunities related to the ATM Data Services Provision (ADSP) concept
addresses in the legislative proposal SES II+. These opportunities can be taken advantage of
directly by the ENAV Group or through its partnerships (e.g. Coflight Cloud Services) or its
subsidiaries (ESSP, Aireon, etc.).
2023-2025
Projects Description
CoFlight e 4Flight ENAV is also involved, in partnership with the French provider DSNA and the Leonardo -
Thales industrial consortium, in the Coflight programme, which aims to design, develop
and implement a new-generation system for the management of aircraft flight trajectories,
to support increasingly efficient operations management.
Coflight Cloud
Services
As part of the Coflight project, ENAV, together with its partner DSNA, is also involved in the
development of a new concept for the remote provision of Flight Data Processing (FDP)
services, with the Swiss provider Skyguide as a customer. The concept is innovative in that,
unlike normal cases, FDP is provided as a service instead of as a system with operational,
technological and economic benefits.

Customer relations

Among the Stakeholders of the ENAV Group, air navigation companies, together with the other components of commercial aviation, play an absolutely central role as customers of the ATS services provided.

ENAV, through the Operations units most in direct contact with customer needs, Airspace Users, has developed an effective network of relationships over recent years. Proactivity is the hallmark of the system, supported by a network of operational cooperation agreements signed with major air transport operators. By virtue of these relationships and cooperation, ENAV ensures a constant and up-to-date flow of information between providers and customers and consequent involvement in activities. Thanks to the operational appendices included in each agreement, dedicated to professional enrichment and joint training activities, ENAV has an effective tool to understand customers' needs and expectations better, aligning, where necessary, service requirements to the dynamic needs of the aviation sector.

The programmes shared with the companies constitute a consolidated work agenda that, throughout the year, allows for general or specific information activities, such as Open Days, Workshops, Webinars and various meetings.

Among the initiatives introduced by Operations, the plenary web meeting for the implementation of the first Remote Tower, in service in Italy for the airport of Brindisi and managed by ENAV, was of particular interest.

The organisation of customer relations, the user-friendliness of the initiatives promoted and the constant support provided to customers of ATS services give the Customer Relationship service a position close to excellence in customer ratings.

IDS AirNav has activated its own support services for all customers, by means a group dedicated to around 10 people (Customer Care Team, part of the Services area of IDS AirNav) which performs the initial analysis of the requests for technical support made by customers (users of the IDS AirNav system/SW). This initial support phase can end with instructions (or procedure) for the removal of the problem that was presented and/or in direct support in the use of the system/SW or with a workaround that can be defined permanent or temporary.

When managing customer satisfaction, the Freshdesk tool can be used to generate a series of different types of indicators that make it possible to monitor:

  • the number of support requests made (open, closed, in progress, pending, etc.).
  • the systems/SW for which support requests are received.
  • the average resolution time (distinguishing between solutions reached in the first phase and those following timeframes linked to developments on the system/SW code).
  • the reasons for requests that can be solved during the initial support phase.
  • the system/SW solutions for which most requests are received.

These indicators are provided to the various figures in the Company organisation that need these details in order to:

  • define/adapt/start commercial actions and/or strategies.
  • solicit greater attention and/or support in the technical management of the customer.
  • directing energies and means towards those areas (or sub-areas) of the system/SW that present problems most frequently.
  • extrapolate common elements for the medium/long term development plans for the system/SW.
Future goals Deadline
Maintain response times for support tasks that do not require development (TR/CR) or
hot-fixes.
Q4 2023
Continue with the standardisation of reports on the status of customer service activities
towards customers.
Q4 2023

The sustainability network

Active participation in a series of networks focused on sustainability is a commitment that the Company has made and continues to make with determination, in the knowledge that engaging with the policies and projects developed by other companies, regardless of sector, is a valuable element of learning and growth.

Sustainability Makers

Sustainability Makers is a reference association for professionals dealing with sustainability and corporate social responsibility in their capacity as Company managers, consultants and researchers, one with over one hundred managers and professionals dedicated to issues of Corporate Social Responsibility. ENAV's commitment is also substantiated by the participation of its Head of Sustainability and CSR on the Board of Directors of Sustainability Makers.

Fondazione Global Compact Italia

Since January 2021, ENAV has been part of the Global Compact Network Italy Foundation, which makes the Network's its own and undertakes to spread knowledge of the United Nations Global Compact (UNGC) by favouring an increase in membership in Italy and by promoting a commitment to encourage corporate sustainability on the part of participating Italian companies and organisations.

Salone della CSR e dell'innovazione sociale

Since 2019 ENAV has taken part in the Salone della CSR e dell'Innovazione Sociale, the most eagerly awaited event among sustainability advocates. Recognised as the main event in Italy dedicated to CSR, the Salone has contributed to the spreading of a culture of social responsibility, provided opportunities for updating attendees and facilitated networking among the various social players.

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ASVIS

ENAV is a member of the Italian Alliance for Sustainable Development (ASviS - Alleanza italiana per lo Sviluppo Sostenibile), an association founded on 3 February 2016 on the initiative of the Fondazione Unipolis and the University of Rome "Tor Vergata". The aim is to increase knowledge in Italian society, in businesses and in institutions of the importance of Agenda 2030 for sustainable development and to drive them into achieving the Sustainable Development Goals (SDG) through:

  • the development of a sustainability culture at all levels, orienting production and consumption models to that end.
  • analysis of the implications and opportunities for Italy associated with the Agenda for Sustainable Development.
  • a contribution towards the definition of an Italian strategy targeted at the achievement of the SDGs (including by the adoption of analytical and predictive tools that assist in the definition of sustainable development policies), and the realisation of a monitoring system of Italy's progress towards achieving SDGs.

EticaNews

ENAV is part of the ET.group, a project developed around ETicaNews, devised by a group of journalists and professionals. The publication was founded along three guidelines:

  • journalism on ethics, i.e., dealing with themes that both promote and give voice to a society that is sustainable from an economic and social perspective.
  • ethical journalism, meaning that it is independent of advertising, political or relational links, placing itself under the guarantee of an ethic-scientific committee.
    • wikietico journalism, i.e., a type of journalism that aims to give voice to the network of Stakeholders and readers and to involve them in the project.

CEO for life awards is an initiative founded by HR Community, which brings together the CEOs of the most important companies in Italy committed to sustainable development and to which ENAV has been signed up since 2021.

Sustainable Infrastructure Association (AIS)

AIS is a technical-scientific association, which characterises itself as a think tank of excellence, positioning itself as an authoritative and valuable interlocutor for public and private institutions.

The main objective of the Association is to foster the dissemination of a broad and qualified culture of sustainability and an increasing awareness of the social and economic value of having sustainable infrastructure.

3. People

The Group's people are the key factor in designing and making sustainable the sky of the future. Thanks to the dedication and professionalism of its people, the ENAV Group is able to provide services of the highest quality for air transport, while maintaining a constant commitment to creating an inclusive, collaborative and sustainable working environment in which everyone can feel valued and involved.

Sustainability culture

Ever since the ENAV Group decided to invest decisively in sustainable development, one thing became immediately clear: in order to achieve any goal, it is necessary to start with people.

In ENAV, the human factor is decisive and any objective must necessarily be shared at all levels. However, developing a "culture of sustainability" is more than a corporate objective. In fact, this meant starting a real journey to raise awareness on the topic of sustainability.

For this reason, in order to spread the "culture of sustainability" in ENAV, a three-pronged strategy was developed.

MOTIVATION CAPABILITIES ACTION
Inspire Inform Engage
To motivate change, we
leverage positive examples
(internal ambassadors and
external guests)
To help people along their
path, we offer practical
information and resources
that remove the obstacles
We help people act by
means of simple activities,
which are possible for
everyone

The sustainability ambassadors

Sustainability ambassadors are ENAV people coming from different Company functions and offices and act as a "megaphone" for all the activities connected to ESG topics; they are people with considerable interest in the topic who are assigned to spreading the culture of sustainability within the ENAV Group. In 2022, the group of ambassadors consisted of around 50 people.

The portal of sustainability in the new intranet

The initiative, called "Portale Sustainability", is included within a wider initiative called "JO.DI.E. – JOurney for DIgital Enav", which has the objective of the digitalization of the majority of Company processes and opening of new digital channels and modern and innovative technologies. The sustainability area dedicated to ENAV people is updated continuously and organised in 4 areas: the Sustainability ENAV News, the Sustainability World News and the Library of sustainability documents

Sustainability focus group

In order to involve employees also in the phase of defining and planning new initiatives, focus groups are created in order to present the training requirements and define with them the most suitable initiatives for creating a new sustainability culture. The purpose of all of this is to promote the sharing of and engagement in the new sustainability initiatives.

The sustainability APP for ENAV people: AWorld

AWorld is the app for living sustainably in the modern world. Created to support ActNow, the United Nations campaign for promoting individual actions on climate change, the Aworld app was customised for ENAV and made available to all people of the Group in order to create, through educational games and pills greater awareness of the ability of every one of us, in our small and simple gestures, to save the planet.

Diversity and inclusion

For the ENAV Group, promoting diversity and inclusion is a moral imperative, because everyone has the right to express themselves to the best of their abilities in a working environment that is fair, inclusive and respectful of individual differences.

The ENAV Group has equipped itself with a Diversity and Inclusion Policy, with a view to concretising its commitment to enhancing the value of its human resources and promoting the support of policies in favour of inclusion, diversity and equal opportunities.

The Policy is inspired by national and international reference principles and values in the field of diversity and inclusion, including the "Charter for Equal Opportunities and Equality at Work" promoted by Sodalitas, the UN Global LGBTI Standards for Conduct, the UN Women and UN Global Compact - Women's Empowerment Principles, the United Nations Equal Pay International Coalition (EPIC).

In 2022, a dedicated Organisational Structure - Talent Experience, Diversity and Inclusion Initiatives - was set up with the mission of gathering and directing initiatives capable of promoting an inclusive culture and enhancing everyone's skills.

In addition, in January 2023, a new Trust Advisor (a specialised, external and impartial figure) - provided for in the Regulation on Abuse, Harassment and Violence in the Workplace, which the ENAV Group has adopted - was appointed to manage and carry out functions to prevent and combat discrimination, abuse and harassment in the workplace. The Adviser works in cooperation with the HR department and the Equal Opportunities Committee, activating processes for the care and protection of labour relations at risk of discrimination or harassment.

Preventive actions include training processes and Diversity and Inclusion initiatives, as well as the appointment of a Confidence Advisor, in agreement with the Equal Opportunities Committee and the threeyear Plan of Positive Actions 2022-2024 drawn up by the latter.

In November 2022, a training activity on the subject of "Diversity and team management" was launched for the ENAV Group's middle management, which will be completed during 2023. As part of this activity, 66 heads of organisational structures were involved.

In addition, during 2023, the entire Company population will be involved in e-learning training on the topics of workplace harassment and unconscious bias, and cross-Company mentorship initiatives will be promoted to foster the exchange of professional experiences and enhance existing skills.

Membership of the Valore D network of companies will allow constant updating of the corporate population on D&I issues with the dissemination of best practices (by way of example, the Group is currently adhering to the ValoreD4STEM campaign aimed at enhancing the skills of STEM women).

In cooperation with the Equal Opportunities Committee, a preliminary assessment of the UNI/PdR 125:2022 Gender Equality Certification was initiated and will be developed in 2023.

The "ImproveYourself" project, aimed at ENAV Group people with disabilities who, on a voluntary basis, were able to undertake a skills assessment course, with the aim of guiding their career path through the recognition and enhancement of their skills and personal aspirations, ended in 2022.

The positive impacts generated by the promoted initiatives are constantly monitored through the collection of feedback and the provision of specific moments of sharing with internal Stakeholders. Moreover, downstream of the various activities undertaken (reporting by the Confidence Advisor, monitoring of training and development processes for fragile workers, possible outcomes of the Gender Equality Certification,

Project aimed at new-parent workers in the validation phase), it will be possible to orient subsequent actions according to the evidence that has emerged.

Interaction with Stakeholders (Equal Opportunities Committee, Company managers and population, HR) enables constant monitoring of inclusiveness issues and their continuous adaptation.

For example, during the training course aimed at ENAV Group middle management, a demand for integration between professional skills and internal experience emerged: projects and actions will follow in this regard to share skills and job rotation opportunities, cross-Company mentorship projects in partnership with Valore D.

Future goals Deadline
Promoting internal and cross-Company communities to foster the development of internal
integration.
End of 2023
Gender equality certification UNI/PdR 125/2022 End 2023_Pre
assessment
Training on D&I issues through training snippets delivered by our partner Valore D End of 2023
Creation of the Equal Opportunities Committee in Techno Sky Group By 2023
Establishment in the territorial entities of a contact person for the central Equal Opportunities
Committee to enable the Committee to be closer to colleagues in these locations with
advantages in terms of both communication and support - Pilot project.
By 2023
Projects Description
"Parenting Project aimed at facilitating the integration of the new parents' experience with
Management" work experience, in order to reduce the risk of dispersion of skills caused by the
project for new temporary break from work and to impact positively on the physiological time of
parents return to work after maternity/paternity leave.
Projects Description
Reverse
mentoring/sharing
of experiences
through
participation in
Valore D actions
Participation in cross-Company reverse mentoring initiatives to foster the
exchange of experiences and expertise.
Maternity and
paternity
protection
Development of a brochure to help workers as parents to inform themselves
about their rights and to be able to reconcile work and lifetime (CPO).
Projects shared
with other Equal
Opportunities
Committees
Mainly study and training on Diversity and Inclusion issues to increase the culture
of respect for diversity starting in the area of leadership.

Management and Development

Elevating people management and development to a corporate priority is the most valuable investment in building a sustainable, innovative organisation that can successfully meet the challenges of the future.

The selection of new talent

The ENAV Group has defined a structured process for personnel selection based on the principles of transparency and equal opportunity. This makes it possible to fully appreciate, without any discrimination, the skills and values of every candidate, and identify those who fully satisfy the needs expressed by the various corporate structures to face the Group's present and future challenges.

In particular, the selection process is governed by an ISO 9001 certified Quality Procedure, which ensures candidates are treated with maximum transparency, equal opportunity, uniformity and objectivity in the assessment criteria, and confidentiality in any personal information provided to the Company.

The ENAV Group also uses an internal selection process whereby employees can apply for positions that are more in line with their areas of expertise and experience.

In order to ensure that the hiring process is impartial and objective, both in-house audits and audits are periodically conducted, and actions for improvement in the management and execution of the process are taken based on the results of these audits.

The selection process

Selection activities aim at mutual acquaintance between the ENAV Group and potential new resources and make up the selection process, which is divided into several steps. The process can be integrated by additional steps depending on the transversal skills required for the job.

During 2022, the ENAV Group consolidated its Employee Attraction strategy, promoting the following activities:

Through its Career Days (digital and in-person, constantly publicised in the "Recruiting Events" section of the site), the ENAV Group meets young talents in search of employment, with the ultimate aim of promoting the ENAV brand and attracting new resources.

Inclusion Job Day

• Event dedicated to people with disabilities

Job Meeting in Rome

• Events focused on engineering disciplines

Stem Girls:

• An event dedicated to young female students, graduates and professionals with an education in STEM courses (Science, Technology, Engineering and Mathematics) looking for employment;

In addition, the LinkedIn Talent Solutions platform was used to carry out external selections and to convey vacancies even more extensively, which enabled a wider pool of candidates to be reached, thanks to the use of job slots and the sharing of specific job postings customised according to hiring needs.

On-boarding of new recruits is followed by established practices aimed at monitoring engagement, performance and development actions necessary to ensure retention of new recruits.

In fact, at least five months after recruitment, the direct manager of the resource is involved for structured feedback on the placement and, at the same time, the relevant HR Business Partner23 conducts an individual interview to deepen the perception and satisfaction of the new joiner.

Future goals Deadline
Identification of 200 resources to integrate within Group Companies. 2023
Participation in recruiting events:

15 February: Virtual Inclusion Job Day
Virtual event dedicated to work for people with disabilities
2023

16 March: Virtual Job Meeting STEM Girls
Opportunity for meeting young female graduates and professionals with an
education
in
STEM
courses
(Science,
Technology,
Engineering
and
Mathematics)

May: LUISS Career Day
In-person event dedicated to students and graduates of LUISS Guido Carli
University

30 May: Job Meeting in Rome
An in-person event targeted towards students and graduates of all universities
in the region of Lazio

11 October: Digital Recruiting Week Live Roma Sapienza
An in-person event at Sapienza University of Rome that includes discussions
between corporate HR and students.

23 HR Business Partners are resources in charge of personnel management and represent the point of reference for human resources requests to the Group's various organisational structures.

Future goals Deadline

23 November: Nazionale Engineering Virtual Job Meeting
Virtual event dedicated to talented young engineers.

December: CV at Lunch
In-person event dedicated to students and graduates of Università degli Studi
Roma
Projects Description
LinkedIn Talent
Acquisition
Telling it in a nutshell, through posts on the Group's LinkedIn page, the main initiatives
concerning Talent Acquisition strategies.
Induction Networking event aimed at new joiners to engage them, increase their sense of belonging to
the Group and foster acquaintance between the different structures.
Open Door In-person event at ENAV headquarters aimed at increasing brand awareness and enhancing
Talent Attraction strategies.
Welcome Kit Implementing caring policies for new joiners, accompanying them from Day 1 in their
development paths.

Development and enhancement

In an increasingly evolving context affected by constant changes, prompted by technological innovations and profound changes in the social and economic landscape, for the ENAV Group it is essential to offer people growth and development paths that are up-to-date and consistent with their needs.

In 2022, a dedicated Organisational Structure - Talent Acquisition, Assessment and Learning - was established with the mission to oversee the recruiting and internal assessment process as well as the human capital development lifecycle ensuring, among other things, career path planning.

Fifty-four development assessments were carried out during the reporting year, with the dual aim of assessing the expendability of people to fill specific roles and identifying high-potential resources for whom to create ad hoc development paths in the short to medium term.

At the same time, 15 individual coaching courses were set up to strengthen the less-attended areas that emerged during the development assessment. Along these pathways, the direct managers were also involved in the definition of development goals in order to be able to create "on-the-job gyms" for the growth of the individual.

In addition, the performance management process targeted at all ENAV Group people aims to take an annual snapshot of performance and identify development plans and merit policies, including with the aim of supporting retention.

Training

Managerial and specialised training activities are provided precisely to emphasise the focus on managing the life cycle of the individual within the Company, with a special focus on their development needs.

The ENAV Group has formalised a specific procedure aimed at regulating the management of training activities, which includes - among other things - the definition of an Annual Corporate Learning Plan.

This Annual Plan is designed from different inputs:

In defining the Annual Corporate Learning Plan we therefore paid special attention not merely to strategic drivers and the needs emerging from the organizational units, but also to the integration of training plans with the wider human resources management system.

The consolidated adoption of distance learning and the subsequent reintroduction of some classrooms in synchronous mode, in tandem with the evolution of emergency regulations, made it possible to provide about 60,000 hours24 of training for the ENAV Group's corporate population in 2022.

The training activities were divided into five areas of intervention:

24 Operational training hours are not included in the calculation of training hours.

indispensable for working

47,148 hours 4,105 people

•Mandatory training courses that fulfil regulatory obligations, in areas such as occupational health and safety, Legislative Decree 231/01, GDPR 679/2016, Information Security, Airport Security and Travel Security. They were held asynchronously via the Learning Management System with automatic registration processes or defined by procedures, in order to reach all those concerned in the company

•Refresher on Occupational health and safety

  • •Anti-corruption 2022: ISO 37001 and Whistleblowing Regulation
  • •Market Abuse and Privileged Information

STAY ON BUSINESS efficiency prerequisites 3,295 hours 308 people

•Projects directed towards the development and consolidation of fundamental work skills, such as IT and language skills. They are carried out synchronously and asynchronously and, as regards language training, differentiated courses are offered based on individual needs: from e-learning to one-to-one and thematic workshops in the foreign language

•Synchronous and asynchronous training on the Office suite

•Language training in e-learning mode, mixed (e-learning and live conversations), one-to-one and thematic workshops in English

STAY UP TO DATE

continuation training of individual roles

5,895 hours 447 people

•These courses provide the answer to specific individual needs with the goal of keeping professional skills aligned with the evolution of the organisation and the context. They are held synchronously and asynchronously, with the use of external suppliers or expertise available within the Enav Group.

•Digital Skill Upgrade, a series of workshops dedicated to exploring new and emerging technologies in the world of work.

•Learning Square, initiatives created by the HRCommunity for the professional update on topics relevant for the organisations.

  • •Courses on Audit techniques directed towards personnel in various organisational structures, in order to uniform the methods for managing the quality processes.
  • •HAL training, an asynchronous training path developed in-house to guarantee the updating of all TechnoSky personnel involved in the introduction of the new method of managing maintenance operations (TOC).
  • •Prometeo, training course dedicated to the introduction of the new application for special waste management.
SUPPORT CHANGE
a plethora of opportunities for individuals and groups
465 hours
288 people
•Projects and paths developed with the aim of accompanying the processes of
organisational change that range from self-education through paths of "training
pills"
targeted
towards
the
creation
and
individual and Group coaching
consolidation of work
groups, to
•Continue the delivery of "training snippets" on soft skills topics.
•Launch of a series of digital resources dedicated to increasing digital skills and
mindset.
•Agenda 2030, a course dedicated to understanding a new corporate culture,
towards circular economy and sustainable finance tools.
•Individual coaching paths dedicated to high potentials.
2,004 hours
strategic training 142 people
GROWTH
•Programmes and initiatives dedicated to groups of people – such as new hires
and
newly
promoted
managers
-
in
order
organisational development.
•Course
for
newly
appointed
managers:
a
to
promote
individual
and
course
that
alternates
between
classroom sessions and individual coaching with the goal of developing the
leadership skills of middle management.

*The total hours of training provided include specialist management, legal and language training (environmental, WHS and operational training hours are excluded).

Operational training

In-house training of ENAV Operative personnel

Being an Air Traffic Controller (ATC) requires constant attention and safe and efficient operational behaviour. The internal training of ENAV operational staff is aimed at transmitting the skills necessary to operate in a highly reliable environment.

Indeed, whether they are in front of a monitor with lighted indications, or in an airport control tower, ATCs must constantly demonstrate their skill and ability to direct and manage the pilots with whom they are in constant radio contact. The air traffic controller performs a series of on-the-spot assessments related to the safety and efficiency of the assisted aircraft to ensure the continuous maintenance of separation (minimum vertical and horizontal distances) between aircraft in flight.

For these reasons, ENAV pays special attention to the development of skills through classroom and on-thejob training, which are decisive factors for reaching the goals.

The training of Air Traffic Controllers, Flight Information Service Officers (FISOs) and aeronautical technicians is ensured by a dedicated organisational structure, whose mission is to oversee the training of air navigation services for both ENAV Group operational resources and external customers.

The training courses are modulated in accordance with the educational standards laid down by sectoral, national and international regulations, with particular reference to the Single European Sky regulations.

Because of this, certified and uncertified training design activities must meet certain general requirements in order to achieve the highest quality levels. ENAV therefore defines specific targets to achieve in developing its training, such as:

  • to clearly define the general goals and specific objectives that the training aims to achieve.
  • to break down the objectives of skills development in terms of knowledge, ability and behaviour.
  • to define the process conditions and the teaching methods necessary to conduct the training and the system of verification of the objectives.

Each training programme must therefore always provide information on the structure and duration of the training, the methods of delivery, the characteristics and needs of the target population, the teaching objectives and the applicable reference legislation.

In 2021, the effects of the pandemic led training to focus on competence maintenance programmes, through the "Back-To-Normal" programme, which provided training for operational personnel in a simulated environment, in anticipation of a future resumption of air traffic. In 2022, however, the focus of training shifted to the initial training of new hires.

Hours of internal operational training (classroom and e-learning) ENAV

In-house training of TECHNO SKY Operative personnel

Technical operational training is also provided by Techno Sky, in particular through specific training courses for technical personnel involved in the operation, maintenance and installation of communication, navigation, surveillance and air traffic management systems.

The following courses were delivered during 2022:

▪ Technical training courses for ATSEP personnel (except Basic and Qualification training) to acquire the necessary skills to operate CNS/ATM equipment used by ENAV for air traffic control.

▪ Technical training courses for technical-engineering personnel not related to ATSEP competencies: these are technical courses on specific topics required for the activities of the Operations and Technology Unit.

In-house training of IDS AirNav Operative personnel

In continuity with previous years, the management policy for technical-operational training is based on the facilitation/organisation of the following modalities:

  • Study/self-study (possibly supported by internal tutors).
  • Classroom or e-learning training sessions delivered by both IDS AirNav internal personnel and external instructors, either from the ENAV Group or outsourced.
  • Operational coaching (contextual to the activities of existing "AIM Solution" projects).

For 2022, training initiatives for internal staff were aimed at the following objectives:

• Internal refresher course on developments in IDS Air Nav AIM Suite SW products.

• Improvements to or acquisition of enhanced international language skills necessary for the provision of the various activities and/or services offered by IDS Air Nav.

Future goals of IDS-AirNav Deadline
2023
Training courses on the typical areas of the Services unit are planned for 2023.

Improving or acquiring greater expertise on some of the non-IDS (third party
HW/SW) technologies integrated into the SW products of the IDS Air Nav AIM
Suite.

Improvement or acquisition of more management skills used in team
management for responsible persons only.

Improvement or acquisition of increased skills in communication aspects (public
speaking), preparation of related material (slides, support material, exercises,
etc.) both live and pre-recorded.

Updating or acquiring of greater expertise in training delivery
methods/processes/techniques.

Update on quality processes and support tools used to implement both the
management/release cycle of IDS Air Nav's AIM Suite SW products.

External Operational Training

The training delivered to third parties is targeted towards professional positions closely related to air traffic control and people working in various areas of the aviation sector who require special training courses in flight navigation (e.g., airlines, airport operators, air traffic management services, aeronautical industries, and government bodies in the air transport sector).

Thanks to its ability to develop scenarios and operational specifications that are adaptable according to the course objectives, even building airport scenarios and personalised service areas, the ENAV Operational and Technical Training unit can tailor training courses to match the customer's specific logistical and organisational needs.

When defining training activities for external parties, the ENAV Group pursues the same objectives of excellence that characterise the management of training activities for internal staff.

As was to be expected as the Coronavirus-related emergency progressed, 2022 marked a return to normality with respect to supply to the third market.

The ENAV Training Centre works with local institutions, particularly with those engaged in the training system: the Francesco Baracca Aviation School, the Faculty of Engineering of the University of Bologna, and ISAERS (a consortium that promotes and develops training and research activities in aeronautics and aerospace within the Forlì Aviation Technology Hub). The presence of the Training Centre in Forlì has had a significant impact on local development over the years, also through:

  • •improvement in education levels owing to the presence of new training opportunities.
  • cooperation with local businesses and support for innovation processes.
  • contribution to the development of the Aerospace Technological Centre, which has had a positive effect in making the area more attractive.
  • greater visibility of the territory in the media.

In addition, the collaboration with the University of Bologna continued for the Academic Year 2021/2022, where the Training Centre staff will teach Air Traffic Control, two training modules envisaged in the Study Plan for students attending the Faculty of Aerospace Engineering. Lastly, it should be noted that the ENAV Training Centre's actions in relation to the Forlì area do not end with its contribution to the world of education. In terms of relations with institutional Stakeholders, the Training Centre cooperates with the Unindustria association and Fondazione Cassa di Risparmio di Forlì.

Social policies and corporate welfare

The ENAV Group firmly believes that the well-being of its people is essential to their happiness and success, and has therefore implemented corporate welfare policies aimed at improving the quality of life at work. Moreover, the ENAV Group is committed to designing and planning projects aimed at improving work-life balance, through a careful policy of listening to internal Stakeholders through the promotion of targeted surveys.

Effective welfare cannot disregard adequate listening policies, aimed at defining people's needs and expectations, which ENAV has introduced in order to be able to offer useful and appreciated services and benefits, thus also defining the scope of action.

AREA PROJECT ACTIVITIES
Social policies Prevaer
Supplemental
Pension Fund
The ENAV Group contributes 3% of the member's salary to the
fund, in addition to the 2% paid by the member.
New Routes In order to support people who are approaching the end of their
working career, the ENAV Group proposes a Life Coaching course
to face this important moment of change in the best way possible.
"New Routes" takes place through four sessions (two before and
two after the retirement date) of Life Coaching, each of an hour
and a half.
Insurance
policies
Health
Supplementary
Health Insurance
This policy insures the person and their nuclear family in case of
illness or accident and covers medical and health-care expenses
both for hospitalisation as well as non-hospital expenses
(specialist examinations and diagnostic exams), with a premium
paid fully by the ENAV Group. The person is only responsible for
paying the premium of non-dependent family members.
Preventive care
packages
Medical and dentist checks are also provided, with general and
specific packages depending on gender and age.
Policy for problems
in the nuclear family
This includes expenses paid for therapies for children with
learning disabilities, behavioural problems, development issues
and autistic spectrum disorders. Furthermore, this policy also
provides coverage in the case of illness due to COVID-19.
Accident insurance Compensates persons of the ENAV Group in the case of
permanent invalidity caused by accidents that occurred during
work or non-work activities.
Yes We Care With this project, which was launched in 2019, the ENAV Group is
seeking to increase awareness among Group people of the
importance of prevention and a healthy lifestyle by organising
health-related events with physicians and other experts. Also the
collaboration with the Onda Foundation - National observatory
for women and gender's health – promoter of the project HFC
(Health Friendly Company), placed greater attention on people
health through quality information tools targeted towards
acquiring greater awareness about the main gender-specific
diseases, mental health and the importance of prevention and
the adoption of correct life styles.
Emotional support
(30 minutes for an
emotional
switch
that makes the day
better)
An experimental project aimed at preventing psychological
distress was initiated and completed in 2022. The main objective
was to create an environment conducive to emotional well-being
and to provide each person with the necessary tools to manage
their emotional emergencies effectively, through interventions
aimed at rapid relief.
AREA PROJECT ACTIVITIES
Family Parental leave The ENAV Group pays its new parents their full salary during
parental leave, whereas current social welfare regulations
provide for 80%. In addition, it offers the possibility of being
absent from work for six months, extendable up to the child's
third birthday, with 80% of salary for the first two months and
40% for the next four, unlike the current legislation that provides
for 30% for the entire leave period. In addition, the ENAV Group
provides parents with support tools such as paid leave in the
event of their children's illness (with 50% pay for the first 30 days,
not provided for under current legislation), and paid leave for
specialist medical services.
Work-life
balance
"Solidarity holidays" All people of the ENAV Group can assign a portion of their
holidays to the benefit of co-workers experiencing particularly
challenging family situations. In addition, the initiative has also
been extended to persons who, within their own family, need to
care for their parents, spouse, cohabiting partner and adult
children.
Money saving Platform for the
provision of
corporate welfare
services
It allows ENAV people to convert their performance bonus into
benefits through the purchase of goods in kind (shopping,
shopping, fuel) and services (sport & wellness, travel, training).
The conversion percentage for ENAV is 10.2%. This platform was
also activated for Techno Sky employees with a conversion rate
of 14.5%.
The platform also remains open to IDS AirNav for the use of the
Company welfare bonus provided by the Metalworking Collective
Bargaining Agreement.
"Corporate Benefit"
and "Vip District"
discount portal
These discount platforms provide ENAV Group people with
extensive benefits in the fields of banking, insurance, leisure,
culture, mobility and fitness. In addition, further agreements
were made with companies and organisations, with a special
focus on those offering products and services with an ethical
environmental vocation (e.g., purchase of electric vehicles, sales
against food waste).
Meal vouchers The ENAV Group provides the "Canteen Replacement Service"
rendered through the disbursement of meal vouchers (provided
both in the presence of a Company canteen and during agile
workdays).
Combating food
waste
Agreement with
ThinkAbout
An innovative socially oriented start-up whose NO.W© (NO
Waste) project is designed to assist the drive to reduce food
waste, allowing consumers to take advantage of discounted
prices to purchase very high quality products that would
otherwise be destined for disposal, since they are not marketable.
Let's talk about This new project, introduced in 2022, replacing the Open Project,
broadens
the
target
group,
having
introduced
dedicated
pathways for both 16- to 19-year-olds and 20 to 28 year-olds.
For the former, the project offers the opportunity to meet with
mentors and HR during two webinars, take part in quizzes on
academic orientation topics, and discover trends on the most
AREA PROJECT ACTIVITIES
Support for
education
popular
universities
and
study
paths.
31
young
people
participated with a level of satisfaction ranging from 4.3 to 4.8
(Likert scale 1-5).
For older children, during the three webinars organised the
project is intended to combine direct dialogue with recruiters, the
telling of the stories of ENAV professionals, the discovery of the
new roles most in demand in companies and advice on job
profiles to develop an active job search strategy. 49 young people
participated with a level of satisfaction ranging from 4.0 to 4.7
(Likert scale 1-5).
Teaching visits With this project, the ENAV Group ensures that technical
institutes and Faculties in the aeronautical field and beyond can
make educational visits to our facilities (Control Towers and ACCs)
throughout the country. In 2022, the institutions involved (23 in
all) took more than 1,000 students to visit 20 different sites. The
visits, which took place between March and May, were
coordinated with the operations staff, who were in charge of
illustrating to the young people, teachers and accompanying
persons the organisation of air traffic control activities and the
operation of the support equipment.
Mobility Shuttle service and For the headquarters in Rome, synergies were developed with the
parking Istituto Poligrafico e Zecca dello Stato:

The use of the Istituto Poligrafico e Zecca dello Stato car
park to increase the number of places available for ENAV
Group personnel.

A shuttle service connects the car park of the Istituto
Poligrafico e Zecca dello Stato with ENAV headquarters.

A shuttle service from the main local public transport
hubs (Tiburtina and Nomentana stations) to ENAV
headquarters.

Occupational health and safety

Aware of the importance of preserving the health and safety of its own people and third parties, the ENAV Group is dedicated to promoting a healthy and safe working environment. This commitment takes the form of a careful risk assessment, aimed at minimising the risks arising from work activities, and the adoption of appropriate safety measures, including numerous prevention, training and awareness-raising activities aimed at disseminating and consolidating the culture of health and safety in the workplace, developing risk awareness and promoting responsible behaviour by all personnel.

With the aim of pursuing the strategic objectives identified within the Group's Health and Safety Policy and in general the continuous improvement of occupational health and safety performance, the ENAV Group Companies have adopted an Occupational Health and Safety Management System (SGSSL) compliant with the international standard ISO 45001:2018 and in compliance with the Italian regulations pursuant to Legislative Decree 81/2008.

In compliance with statutory legislation, the ENAV Group pursues the key objective of ensuring continuous improvement of its performance in relation to occupational health and safety and the elimination or reduction of risks affecting all Group personnel and any other Stakeholders who may be exposed to occupational health and safety hazards associated with their work activities. In fact, the Health and Safety Policy is shared at all levels of the Company, through publication on the portal.

On the whole, the System applies to all personnel belonging to the Group, permanent and temporary, managerial and non-managerial, workers of third-party companies who work in the Group's workplaces as part of contracts, as well as external visitors.

Within the ENAV Group there is an organisational structure that performs the role of supervision, direction and coordination over all the Group's Italian companies, headed by the Prevention and Protection Service Manager. There is also a system of employer delegations and sub-delegations in the field of occupational health and safety. Regular meetings pursuant to Article 35 of Legislative Decree 81/2008 are held annually in all ENAV Group Companies.

In relation to health and safety in the workplace, in compliance with relevant requirements, the employers carry out risk assessments for ENAV Group Companies, including the risk related to work activities in other countries, drawing up the associated Risk Assessment Reports (RAR).

The Risk Assessment Documents (RAD) were updated in 2022 for ENAV, Techno Sky, IDS AirNav and D-Flight.

The ENAV Group has adopted an internal procedure - included in the procedural body of the Health and Safety Management System - which describes the process of reporting, recording and analysing hazardous incidents with the aim of ascertaining possible areas for improvement in the field of occupational health and safety, identifying the need for corrective action or the opportunity for preventive action, communicating the results of investigations and preventing undesirable events with a view to continuous improvement.

In order to respond promptly to situations that may cause a potential emergency, the ENAV Group has defined and implemented, and kept constantly updated, the Emergency and Evacuation Plan of the individual sites, trained and designated an adequate number of emergency management personnel and organised periodic fire drills.

Within the Group, the health surveillance service is guaranteed as provided for by Legislative Decree No. 81/2008, as amended, which, in view of the location of the sites where staff work throughout the country, is ensured by a staff of medical officers (MO), under the direction of a health coordinator (HC).

During 2022, local committees met to review the implementation of the Shared Protocol for Updating Measures to Combat and Contain the Spread of SARS-CoV-2/ COVID-19 in the workplace.

Finally, a specific procedure included in the Occupational Health and Safety Management System regulates the travel security risk assessment process. In this context, assessments mainly concern factors that may endanger the life and safety of personnel, including others that may affect the very personal rights of the individual, such as deprivation of personal liberty due to arbitrary acts of authority or phenomena of intolerance based on ethnic, religious or sexist grounds.

In the context of business relations, the Italian Companies of the ENAV Group ensure the prevention and mitigation of all impacts, related to health and safety, through the application of the Health and Safety Management Systems adopted.

Worker training concerning occupational health and safety

As far as occupational health and safety training is concerned, ENAV ensures the provision of training courses for all the workers of the Group's Italian companies, as defined in Article 2 of Legislative Decree 81/2008 as amended, through classroom/videoconference/e-learning sessions. In particular, training activities are aimed at personnel designated as emergency management personnel, workers elected/appointed as workers' safety representatives, and persons identified as Managers or Officers. Courses delivered in e-learning mode on the TOTARA platform concern:

  • General worker training.
  • Specific worker risk training.
  • Worker refresher courses.
  • Travel safety.

In addition to the aforementioned training, the following courses are also delivered to Techno Sky employees in compliance with needs:

  • Standard CEI 11/27 concerning electrical works and qualification for the related jobs.
  • Category III Personal Protective Equipment (PPE).
  • Users of Elevating Work Platforms (MEWP/EWP).
Future goals Deadline
Update of the work-related stress risk assessment for ENAV, IDS AirNav and Techno
Sky
2023
Maintenance of OHSMS certification pursuant to standard ISO 45001:2018 for the
companies in the ENAV Group (ENAV, IDS AirNav, Techno Sky and D-Flight).
2023
Projects Description
HSE software Adoption of a management software in order to make more efficient the
document production process on occupational health and safety for the whole
ENAV Group.

Industrial relations

In the course of 2022, discussions with the employer and worker organisations focused on various operational issues functional to the implementation of the Business Plan, such as the transfer of APPs (approaches) of the radar towers to the Area Control Centres (ACCs), on the reorganisation of the professionalism of the operations rooms, on the personnel policy and the implementation of the digital towers.

A further topic discussed was the 2021 performance bonus (paid in 2022), which was distributed to eligible personnel after the signing of an agreement protocol.

Furthermore, in order to make the organisation of the work of operating personnel even more efficient during the summer period, which is affected by a significant increase in the number of flights to be assisted, in the June-September period, the Company set up an attendance bonus with economic values differentiated according to the type of plant and professional category, functional to the complete performance of all the ordinary shifts in the roster, including taking holidays and recovering abolished holidays, where applicable.

Furthermore, the ENAV Group has actively collaborated with the other functions concerned on the issues of external recruitment of operational staff, professionalisation and geographical mobility of Air Traffic Controllers and Flight Assistance Experts.

In October and November 2022, several meetings were held with the trade union representatives, which led to the signing of a number of agreements relating to operational issues (mainly the timing of the transfer of the Florence, Turin and Venice approaches, to be carried out at the end of the Summer of 2023; maintenance of the salary levels of the personnel concerned, organisation of the operations rooms, geographical mobility and professionalisation) that led to the withdrawal by the trade unions of the disputes in progress on the above-mentioned matters.

In November, the following were defined:

  • Agreement for the definition of the new contractual minimums as of 1 January 2023 with the trade unions FILT-CGIL, FIT-CISL, Uiltrasporti, UGL-TA and UNICA, which defined the recovery of inflation for the period 2018-2022, recognising on the average category an increase - excluded from future revaluations - of about 5.2% compared to the previous contractual minimums.
  • Salary increases for the three-year period 2023-2025 based on ISTAT forecasts for the same period (6%).
  • Company agreement for the definition of one-off amounts for inflation recovery 2020-2022 to fully and definitively cover the contractual holiday period.

Finally, during 2022, 117 meetings were held with ENAV National Organisations and 80 meetings with Company trade union representatives, and there were two national strikes (56.78% average taking part) and five local strikes.

For Techno Sky, the general objectives pursued are the maintenance of a good Company climate through dialogue and meetings with the trade unions and the improvement of the management and productivity of the workforce.

To this end, meetings were organised throughout the year with the aim of supporting an effective dialogue with the social partners.

From the continuous and constructive engagement, excellent results were achieved in terms of relations, leading to the signing of various agreements, aimed both at containing Company costs, such as the agreement on holiday pay, annual paid leave and the time bank (eliminated with the harmonisation process), and at improving the personal economic conditions of workers, such as the agreements on Company welfare, on one-of payments to cover the contractual holiday and the related inflationary recovery.

2022 saw the finalisation, through the signing of a trade union agreement, of the negotiation begun in 2018 to harmonise the working hours applied to Techno Sky staff with the working hours in force at ENAV.

Consistent with 2021, the process of informing and monitoring - towards the national and local trade unions - on the progress and start-up of the Technical Operation Centre project continued, in coordination with the Company's Technical Line.

The number of employees registered with the union stood at 306, or 42.7% of the workforce, in line with the figures for 2021. The number of registered employees is determined on 31 December each year.

With regard to national strikes affecting the entire air transport sector, there was a decrease in the number of days, from 11 in 2021 to 6 in 2022. As a result, the number of strike hours decreased during the year to 135, with a staff participation rate of 0%.

The number of employees covered by collective bargaining agreements of various levels is 717, equal to 100% of non-executive employees.

In line with the provisions of the national collective bargaining agreement, significant organisational changes are communicated in advance to the signatory parties.

Concerning IDS AirNav, the general objectives pursued refer mainly to the continued integration of the Company in the Group's Industrial Relations system, of the ENAV Group.

This objective was pursued through the maintenance of a good Company climate, with continuous dialogue and discussion with the Workers' Representatives Committees and the Territorial Structures of the Metalworking sector, aimed at improving the management and productivity of the workforce.

The main actions taken through meetings also led to the signing of the agile work agreement, in line with Group strategies.

In addition, minutes were drawn up in which a one-off financial reward was provided for all non-managerial staff for achievements attained during 2022.

The number of employees registered with the union stood at 39, or 24.8% of the workforce, in line with the figures for 2021. The number of registered employees is determined on 31 December each year.

No strikes were called in 2022.

The number of employees covered by collective bargaining agreements of various levels is 157, equal to 100% of non-executive employees.

In line with the provisions of the national collective bargaining agreement, significant organisational changes are communicated in advance to the signatory parties.

Future goals Deadline
Renewal of the regulatory part of the national collective bargaining agreement,
Specific Part ATM Services and Specific Sections Strategic Installations and Low Traffic
Installations
December 2023
(TS) Establishment of the Equal Opportunities Committee. 30/06/2023
(TS) Creation of a work group for the update of second level legislation 31/12/2023
(IDS AirNav) Adjustment of Group policies 31/12/2023

4. Governance

In view of the social importance of the ENAV's operations, the main objective of the Company's corporate governance system is to perpetuate the Company's sustainable success, to create long-term value for its shareholders and appropriately balance and foster all the interests involved.

The ENAV corporate governance structure is based on the traditional Italian model, which, save for the powers reserved to the Shareholders' Meeting by law and the Articles of Association, gives the Board of Directors responsibility for the strategic and operational management of the Company, while the Board of Statutory Auditors is charged with performing oversight functions.

According to Principle I of the Corporate Governance Code, the Board of Directors has the role of pursuing the Company's sustainable success, as well as to make decisions about the definition of strategies and monitor their implementation, as well as to establish the most functional corporate governance system for the business and for pursuing its strategies, taking into account the system's space for autonomy. The Board of Directors is supported by the Sustainability Committee to analyse matters relevant to long-term value generation.

In accordance with the provisions of the Articles of Association, the Board of Directors has appointed a Chief Executive Officer, who has been granted all powers for the ordinary and extraordinary management of the Company, while reserving decisions on certain matters to itself.

The Chief Executive Officer is thus the person primarily responsible for the management of the Company, without prejudice to the powers and responsibilities reserved to the Board of Directors.

The Board of Directors also granted the Chair the authority to coordinate internal auditing activities and, together with the Chief Executive Officer, responsibility for managing national and international institutional relations and chairing the governing body. The Chair, in agreement with the Chief Executive Officer, also handles the Company's external communication activities and relations with national and foreign media.

The model adopted by the Company separates of the functions of the Chair of the Board of Directors and the Chief Executive Officer, while both are responsible for representing the Company.

In accordance with the Articles of Association and the Corporate Governance Code, the Board of Directors has set up three internal committees with advisory and proposal-making functions vis-à-vis the Board itself, to which they report through their Chairs at each Board meeting.

Control, Risks and Related Parties
Committee
Remuneration and Appointments
Committee
Sustainability Committee
It supports the evaluations and decisions of
the Board of Directors concerning the
Internal Control and Risk Management
System (ICRMS) and the approval of
periodic financial and non-financial reports.
In addition, it performs the functions
provided for by the Related Parties
Procedure adopted by the Company and
exercises the associated powers, in
accordance with the provisions and
methods laid down therein.
It assists the Board of Directors in activities
regarding appointments and remuneration.
Within the scope of activities relating to
remuneration, the Committee is
responsible for assisting the Board of
Directors in drawing up a policy for the
remuneration of Directors and top
management that is functional to the
pursuit of the sustainable success of the
Company.
It assists the Board of Directors in
sustainability related activities.
The Committee oversees sustainability
policies related to the Company's business
operations and the dynamics of interaction
with Stakeholders.

The Committees constituted within the Board of Directors are all composed, in accordance with their respective regulations, of three non-executive directors, the majority of whom meet the independence requirements laid down by the Code, including the relevant Chair.

The Board of Directors, acting on a proposal of the Chief Executive Officer and taking note of the favourable opinion issued by the Board of Auditors in accordance with Article 18-bis of the Articles of Association, also appointed the Financial Reporting Officer in charge of drafting the Company's financial statements for the three-year period 2020-2022.

The task of performing independent statutory audit functions for the period from 2016 to 2024 is carried out by the audit firm EY S.p.A., which is entered in the register of audit firms and was appointed by the Shareholders' Meeting on 29 April 2016, acting on a proposal of the Board of Statutory Auditors.

The Board of Directors

ENAV's Board of Directors has an appropriate number of independent Directors, with seven out of nine meeting the independence requirement. In this regard, the Board periodically verifies the independence of its own members using suitable formal procedures and under the supervision of the Board of Statutory Auditors.

The qualitative/quantitative methods and criteria for verifying the independence of ENAV's Directors are contained in the Policy regarding the criteria and procedure for the assessment of the independence of ENAV's Directors adopted by the Board of Directors in accordance with the recommendations of the Corporate Governance Code.

As regards gender diversity and balance in the composition of the Board of Directors, the Articles of Association provide for observance thereof in line with current legislation. The substitution and integration mechanisms of the Board of Directors are consistent with such criteria. Similar safeguards are in place for the composition of the corporate bodies of the Group's Italian subsidiaries, in accordance with the provisions of their respective Articles of Association.

ENAV has adopted a Policy on Diversity in the Composition of Management and Control Bodies 25 . In accordance with the provisions of applicable legislation and the Articles of Association on the diversity and professional qualifications of ENAV's directors, this policy offers shareholders and the Board of Directors, each within its own sphere of responsibility, a number of guidelines to ensure the broadest and most appropriate diversity of viewpoints within the governing body, especially with regard to the training and professional development of the directors, proposing processes for monitoring that development.

25 This Policy is published in the "Governance" section of the enav.it website, available at the following link: https://www.enav.it/governance/documenti-societari.

The competences relevant to the impact of the organisation of the Board of Directors are primarily to be found in the relevant provisions of the Articles of Association.

Pursuant to Article 11-bis, the directors must meet the professional requirements set forth by law, current regulations and the Articles of Association, pursuant to which the directors must be chosen in accordance with criteria of professionalism and competence from among persons who have accrued a total of at least three years' experience through the exercise of:

  • activities involving administration or control or management within companies, or
  • professional activities or the teaching of legal, economic, financial or technical scientific subjects at university level, or other subjects that are relevant or in any case functional to the operations of the Company; or,
  • administrative or management functions in government entities or departments, operating in sectors related to the Company's sector, or entities or departments that are not related to the aforementioned sectors provided the functions involve the management of financial resources.

For any other information regarding the requirements for the position of Company Director, please refer to the Corporate Governance and Ownership Structure Report, available on the Company's website26 .

26 https://www.enav.it/governance/documenti-societari

Appointment to and composition of the Board of Directors

Pursuant to Article 11-(2)(3) of the Articles of Association, the Board of Directors is appointed by the Shareholders' Meeting based on slates presented by the shareholders in which the candidates are listed using consecutive numbers. ENAV's directors were selected according to specific criteria of professionalism and competence, with particular concern for experience of at least three years in activities involving administration or control or management within companies, professional activities or the teaching of legal, economic, financial or technical-scientific subjects at university level, or other subjects that are relevant or in any case functional to the operations of the Company, or managerial functions in public entities or public administrations, operating in sectors which are related to the Company's sector, or entities or public administrations that are not related to the aforementioned sectors provided the functions involve the management of economic and financial resources. At the time of accepting their nomination, as well as periodically during their mandate, ENAV's Directors, in addition to declaring that they possess all the requirements of integrity, professionalism and independence, as well as the non-existence of causes of ineligibility, incompatibility and incompatibility, are required to verify whether they have sufficient time to dedicate to the diligent performance of their office27. As required by the specific Regulation, the Board of Directors is supported in the exercise of its powers by one or more Committees with investigative, advisory and proactive functions, whose tasks and composition it defines, taking into account the provisions of the Articles of Association, the recommendations of the Code and best governance practice; in any case, the Council establishes, including in a merged form, the Committees responsible for appointments, remuneration, control and risks, related parties as well as sustainability. The composition, duties and operations of the Committees are governed by specific regulations approved by the Board of Directors, acting on a proposal from the Chair of the Board of Directors, having heard from the Chairs of each Committee. All Board committees are established by resolution of the Board of Directors pursuant to Article 11-(2) of the Articles of Association, and in accordance with the provisions of the Corporate Governance Code. With regard to the rules governing the selection of the members of the Board committees, it should be noted that:

  • the Control, Risks and Related Parties Committee is also composed in compliance with the requirements set forth in Consob Resolution No. 17221 of 12 March 2010 containing the Related Party Transaction Regulation (the RPT Regulation) and the "Procedure for related-party transactions" of ENAV (the Related Parties Procedure). This committee is composed of at least three non-executive Directors, the majority of whom meet the independence requirements laid down by the Code, including the Chair. The Committee as a whole has adequate expertise in the business sector in which the Company operates, functional to assess the relevant risks; at least one member of the Committee has adequate knowledge and experience in accounting and finance or risk management, to be assessed by the Board of Directors at the time of appointment.
  • The Remuneration and Appointments Committee is established by a resolution of the Board of Directors pursuant to Article 11-bis of the Articles of Association, in compliance with the recommendations of the Corporate Governance Code (the Code); this committee is composed of at least three non-executive Directors, the majority of whom meet the independence requirements set forth by the Code, one of whom acts as Chair. Pursuant to the Code, if the Chair of the Board of Directors assessed as independent is appointed by the Board of Directors as a member of the Committee, the majority of the members shall be other independent directors.
  • The Sustainability Committee is composed of at least three non-executive directors, the majority of whom meet the independence requirements set out in the Code, one of whom serves as Chair.

27This assessment is carried out on the basis of the Guidelines of the Board of Directors regarding the maximum number of offices that the Directors of ENAV S.p.A. may hold, which can be consulted in the "Governance" section of the Company's website (https://www.enav.it/governance/documenti-societari).

Role of the Board of Directors in managing impacts28

The Board of Directors - as the highest administrative body - has delegated the management of ESG issues and sustainability strategies of the ENAV Group to the CEO. In order to pursue ESG objectives, the CEO has established the Innovation and Sustainability unit, to which the Sustainability and CSR unit reports, under the CEO's direct authority.

The responsibilities attributed to it at Group level relate to the definition of the objectives inherent to the sustainable development path and the coordination of the evolution of the Sustainability Plan, monitoring its implementation and taking care of its updating in line with the initiatives set out in the Business Plan.

The Sustainability and CSR organisational structure also develops sustainability initiatives in the ESG area and promotes the integration of sustainability issues in the corporate strategy, implementing the climate change, energy and mobility management strategy. This structure is also responsible for sustainability reporting, Stakeholder management, the promotion of the internal dissemination of the culture of sustainability and the implementation of "corporate giving" initiatives in support of socially useful causes. To this end, the Sustainability and CSR structure is divided into three areas of intervention: ESG Performance Management, Stakeholder Management and ESG Project and Sustainability Promotion.

In addition to the above, the Integrated Compliance and Risk Management structure - which also reports directly to the CEO - in its activities of defining and updating the Corporate Risk Profile (CRP) and the related risk assessment, includes the analysis of risks that may have an impact on ESG issues, including climate change.

The system of reporting and information flows to the governing body is formalised, as far as Internal Audit is concerned, within its Terms of Reference and its Manual, as also provided for by the International Standards for the Practice of the Profession to which the Structure is certified.

28 In compliance with the European common enforcement priorities for 2022 annual financial reports, issued by ESMA on 28 October 2022.

Internal Audit reports quarterly to the Control, Risks and Related Parties Committee and half-yearly to the Board of Directors.

In both cases, the Board of Statutory Auditors is also present at the meetings of the two bodies and therefore also receives the periodic reports. The Board of Statutory Auditors as well as the Sustainability Committee, however, periodically convene the Head of Internal Audit to discuss matters on the agenda drawn up.

The reports to the Control, Risks and Related Parties Committee and the Board of Directors contain items of interest, any critical issues detected and any other useful information so that the two bodies are made aware of issues that may have an impact on management and business performance. The information reported includes, in addition to the audit findings, the results of whistleblowing received by the Structure.

In addition, the audits conducted in accordance with an Audit Plan approved by the Board of Directors (and updated during the year also with new elements) are formalised towards - and discussed with - the Chief Executive Officer (also in his capacity as Head of the Internal Control and Risk Management System (ICRMS), the Chair of the Board of Directors, the Risk and Related Parties Control Committee, the Board of Statutory Auditors and, in the case of relevant aspects pursuant to Legislative Decree 231/2001, the Supervisory Body.

In the event of elements requiring immediate attention on the part of the governing bodies, or requiring disclosure, the Head of Internal Audit directly forwards information notes or requests for hearings to address the findings in a timely manner.

The Supervisory Board also periodically submits its report to the Control, Risks and Related Parties Committee (CRRPC) and the Board of Directors, as provided for in its own regulation, to inform on the progress of its supervisory activities on the proper functioning of the 231 Model and to communicate any critical issues that have emerged in the course of its action, regardless of whether the activities were conducted with third parties outside the Company and/or through the Internal Audit action.

In the event of elements requiring immediate attention by the Governing Bodies, the Supervisory Board also directly forwards information notes or requests for hearings to address the findings without undue delay.

Furthermore, the trend of risks inherent to the safety of air navigation services, security, safety in the workplace, environmental protection, fraud and anti-corruption, privacy and trade compliance is periodically reported to the Risk and Related Parties Committee and to the Company's Board of Directors together with the trend of other enterprise-level risks. This communication is included among the Enterprise Risk Management activities that ENAV implements in application of the Corporate Governance Code of listed companies of Borsa Italiana.

Finally, pursuant to the law and the Board of Directors Regulation, the Board of Directors is the recipient of periodic management reports from the Chief Executive Officer. To that end, as required by the Regulation, the Board of Directors establishes the frequency, at least quarterly, at which the Chief Executive Officer provides a report on the exercise of delegations, identifying, with the support of the Control and Risks and Related Parties Committee at least every three years, the applicable materiality thresholds and the necessary claims. On the basis of the information periodically provided to him or her by his or her delegates, on the occasion of the meetings scheduled for the approval of the periodic financial reports, the Chief Executive Officer therefore provides the Board of Directors with a report on the exercise of the delegated powers. In addition, the Board of Directors provides for a precise structure of delegated powers in favour of the Chief Executive Officer, including the provision of types of deeds and value thresholds inherent to the deeds themselves, and to assign certain powers to the Chair.29

Engagement Policy

At its meeting held on 21 December 2021, the Board of Directors of ENAV adopted a policy for managing dialogue with the generality of ENAV's shareholders and other Stakeholders (the "Engagement Policy"), which inter alia outlined and evolved engagement practices, in an appropriately balanced manner and in accordance with best practice, in order to promote, in the most appropriate forms, dialogue with the generality of shareholders and other Stakeholders of relevance to the Company, in compliance with the regulatory provisions in force and the principle of equal treatment of shareholders who find themselves in identical conditions. Said Policy is published in full with a view to maintaining the highest degree of transparency in the governance practices adopted by the Board of Directors, and regulates the methods and forms of direct dialogue between the Stakeholders and the Board.30

As part of its oversight role, the Board of Directors carefully monitors the dynamics of investor relations, including by way of information provided in a standard format, on a fortnightly basis, by the Chief Executive Officer with the support of the Investor Relations structure, which not only addresses the absolute and relative performance of the stock and analysts' evaluations, but also issues of key interest in the dialogue with investors. These include the regulated business and related scenarios, including of a regulatory nature, the non-regulated market, the Business Plan and strategic prospects, also in terms of ESG issues.

Given the Company's growing sensitivity towards ESG issues and their current consolidated integration into its strategies for sustainable success, ENAV also adopts ongoing Stakeholder management methods. These include practices for mapping, identifying and engaging key Stakeholders at Company and Group level, who are considered an integral part of the responsible and sustainable management of the business. These Stakeholders, which include but are not limited to employees, the financial community, airport management companies, carriers and other players in the air transport chain, industry and suppliers and, of course, territorial, national and international reference institutions, are engaged on a regular basis in order to listen with a proactive approach to their requests, concerns and expectations, establish a constructive dialogue with them on material issues of mutual interest and, in the final analysis, orientate choices for the creation of shared value for the organisation and its Stakeholders. In addition to the development of relations with investors and other relevant Stakeholders, where applicable, the dialogue with traditional Stakeholders on industrial and institutional relations is also reported to the Board of Directors on a quarterly basis.

Furthermore, pursuant to the regulations of the Sustainability Committee, established within the Board of Directors, the Committee has - among other things - the task of assisting the Board of Directors and, to the extent of its competence, the CEO in overseeing sustainability policies related to business operations and Stakeholder engagement activities.

29 Considering the plurality of information flows to the Board of Directors and the different types of channels provided for by the set of rules governing corporate operations (by way of example only, the Whistleblowing channel, the Engagement Policy, the Equal Opportunities Committee, etc.), it is not possible - at present - to determine exactly the number and nature of the so-called 'critical concerns' communicated to the governing body during the year of reporting as well as in the previous two years. However, the ENAV Group is evaluating the implementation of a specific process for collecting this information, which will be presented in the next Report.

30 This document identifies and describes, inter alia, the ordinary channels of direct and continuous communication and information for the Company, the Stakeholders (including Shareholders), managed by the competent corporate functions as well as held at Shareholders' Meetings, and represents - alongside other channels (such as the Whistleblowing discipline) - one of the mechanisms for raising critical issues on business conduct made available to Stakeholders.

Furthermore, within the framework of the sustainable development of the ENAV Group and taking into account the strategic relevance of the integration of sustainability in corporate governance and in the initiatives of the Industrial Plan, the strategic ESG Steering Committee was established with the objective of ensuring the coordination of processes and initiatives with potential impacts in the field of ESG issues, taking into account the requests of Stakeholders and the constant flow of information on the relative policies and activities underway as well as on the guidelines, best practices and regulatory updates in the sector.

Responsibilities of the Board of Directors

In addition to the general legislative obligation of directors to conduct themselves diligently according to the requirements of the nature of their office and to their specific skills, the Corporate Governance Code also recommends that they must be aware of the duties and responsibilities inherent in their office. The competence of Directors is not limited to their professional profile, but rather requires attention and constant updating in response to developments in the broad framework of the activity of the enterprise, not only with regard to the business in the narrow sense, but also with regard to developments in the related legislative, regulatory and corporate governance framework, with the primary objective of constantly enhancing the expertise and professionalism of each director.

In order to reinforce the level of competence and professionalism of the members of the administration and oversight bodies, in compliance with Recommendation 12(d) of the Code and the Board of the Board of Directors Regulations, the Chair of the Board of Directors, with the help of the Secretary of the Board itself, ensures that "all members of the management and oversight bodies can participate, after their appointment and during their term of office, in initiatives to provide them with adequate knowledge of the business sectors in which the Company operates, corporate dynamics and their trends, with a view also to the Company's sustainable success, as well as the principles of proper risk management and the regulatory and self-regulatory framework of reference".

To facilitate the members' participation in these initiatives and sessions, the Board of Directors Regulations also provide that, at the beginning of the financial year, the Chair of the Board of Directors – with support from the Secretary – makes available the calendar of induction initiatives for the current financial year.

Since taking office, the Board of Directors of ENAV has pursued in a structured way a broad, structured induction programme, with the support of management as well as, where appropriate, with the support of leading experts in the fields in question, to favour to the greatest extent the increase of specific skills and the onboarding of its members, including specific in-depth sessions on strategic issues.

In the course of the year and as of the date of this Sustainability Report, 5 induction and information and sharing sessions on scenarios and strategic issues have been held. In particular, these initiatives, also conducted with the support of external advisors, concerned: the 2022-2024 Business Plan (28 February 2022); two sessions on the implementation of strategic initiatives aimed at technological and operational excellence (13 April 2022 and 17 October 2022, respectively); digital crisis management (14 November 2022); and the new European Directive on Corporate Sustainability Reporting (20 December 2022).

More information on the induction process carried out by the Board of Directors in 2022 can be found in the Report on Corporate Governance and Ownership Structure.

Furthermore, in accordance with best practice, the Board of Directors regularly carries out a board evaluation exercise, with the support of the Remuneration and Appointments Committee, which is entrusted with the task of assisting the Board in reviewing the methodology used by the appointed independent advisor.

In line with the Recommendations of the Code, the Board of Directors carried out the self-assessment of the Board itself and of its Committees for 2022 with the support of the advisor. The work specifically involved the administration of questionnaires and the conduct of direct interviews with the Directors on the effectiveness, size, composition and functioning of the Board, including through peer-to-peer reviews. The results of the initiative were illustrated at a meeting held on 20 February 2023, during which the Board of Directors conducted its own self-assessment, identifying the strengths of the Board and certain areas for improvement, which will represent the starting point for work on the improvements that may constitute working points for the next board term.

Managing conflicts of interest

With regard to the provisions of Article 2391 of the Italian Civil Code, ENAV's Board of Directors has, for some time now, implemented the practice whereby, at each meeting of ENAV's Board of Directors, the Directors are invited to declare, at the opening of the proceedings, any personal interest or interest on behalf of third parties in connection with the items on the meeting's agenda.

Insofar as the position of the Directors is relevant herein, having regard to the contents of Article 2391-bis of the Italian Civil Code, concerning transactions with related parties, of Legislative Decree 49/2019, and transposing Directive 2017/828/EU ("SHRD II") and the amendments subsequently made (by way of Resolution No. 21624 passed on 10 December 2020) to the Related Parties Regulation, the Company approves related-party transactions in compliance with the provisions of the current laws and regulations, with its own Articles of Association, and with the procedures adopted in this regard. ENAV's current "Procedure for related-party transactions" ("RPT Procedure"31) adopted in compliance with the provisions of the applicable legal and regulatory framework, was last updated, taking into account the latest regulatory changes, by ENAV's Board of Directors on 1 July 2021, having obtained the opinion of the Control, Risks and Related Parties Committee.

Furthermore, ENAV's Board of Directors approved the new Code of Ethics at its meeting on 24 March 2022.

The rules of the Code of Ethics apply without exception to corporate bodies, management, employees, external collaborators, business partners, suppliers and all those who have relations with the Company (including non-subordinate collaborators) and, in general, with the Companies of the ENAV Group. The Code of Ethics regulates the set of rights, duties and responsibilities that ENAV expressly assumes towards the Stakeholders with whom it interacts on a daily basis in the performance of its activities.

The set of ethical principles and values expressed in this Code of Ethics shall inspire the activities of the addressees, taking into account the importance of their roles, the complexity of their functions and the responsibilities entrusted to them for the pursuit of the purposes of the Company itself.

The ENAV Group recognises the importance of ethical-social responsibility in the exercise of its mission and institutional tasks, aspiring to maintain and develop relationships of trust with its Stakeholders. Ethics orientation is an indispensable approach for the reliability of the Company's behaviour towards shareholders, customers and, more generally, towards the entire civil and economic context in which the Company operates.

Furthermore, the Code of Ethics follows the principles set out in the "Code of conduct for public employees" referred to in Presidential Decree 62 of 16 April 2013, issued by the Government to "ensure … compliance with the constitutional duties of diligence, loyalty, impartiality and exclusive service in the public interest".

For the above reasons, it was important to clearly define the set of values that ENAV Group Companies recognise, accept and share and the set of responsibilities that they assume internally and externally.

31 https://www.enav.it/governance/documenti-societari.

These requirements are met by the drafting of the Code of Ethics, which constitutes a code of conduct the observance of which is of fundamental importance for the good functioning, reliability and reputation of the ENAV Group and the non-compliance with which may give rise to disciplinary measures.

Corporate Integrity

The development of an integrated sustainability is based on a solid and efficient governance structure, which promotes ethical business conduct and transparent communication of information about ENAV's operations, with a view to the creation of shared value between ENAV and its Stakeholders.

In order to manage activities and relations in the light of these principles, all Stakeholders - internal and external - are required to strictly comply with the law and the behavioural and procedural rules adopted and implemented within the ENAV Group over time, with a view to developing constructive relations and therefore creating value in relations with Stakeholders.

To this end, ENAV has adopted a Code of Ethics which sets out principles and rules of conduct that contribute to affirming its credibility and reliability in the civil and economic context in which it operates.

In compliance with the provisions of Legislative Decree 231/2001 ("Decree 231"), the Company has also adopted the Organisation, Management and Control Model referred to in Decree 231 (the "Organisational Model"). The Company's Model was updated taking into account the experience gained, the evolution of case law and doctrine, as well as the regulatory changes of Legislative Decree No. 231/2001.

In accordance with Decree 231, the Supervisory Body is tasked with supervising the functioning and compliance with the Organisational Model and the Code of Ethics, as well as to update it with regard to the evolution of the organisational structure or the regulatory context of reference. In addition, specific training activities on the Organisational Model are carried out through communication channels to involve all employees of the Company and the ENAV Group.

These important documents are also joined by:

i) the "Human Rights Policy" containing the reference principles and commitments undertaken by the ENAV Group itself for the protection and promotion of human rights in the performance of its business activities and in every context in which it operates. ENAV endeavours to promote the standards enshrined in international regulations and internal codes to some of the Group's main Stakeholders: employees, customers, suppliers and business partners.

(ii) the "Diversity and Inclusion Policy", with a view to concretising the commitment to sustainable development, including through the enhancement of its human resources, by promoting the support of policies in favour of inclusion, diversity and equal opportunities. The Policy is inspired by national and international reference principles and values in the field of diversity and inclusion, including the "Charter for Equal Opportunities and Equality at Work" promoted by Sodalitas, the UN Global LGBTI Standards for Conduct, the UN Women and UN Global Compact - Women's Empowerment Principles, the United Nations Equal Pay International Coalition (EPIC).

iii) the "Environmental Policy", with the aim of considering the environmental risks and opportunities connected to the performance of the ENAV Group's activities, in accordance with international, EU and national legislation.

(iv) the "Occupational Health and Safety Policy", with the aim of continuously improving occupational health and safety performance and eliminating or reducing risks for all ENAV Group personnel and other Stakeholders.

These policies32 are approved by the Chief Executive Officer of the Parent Company and apply to the entire Company population - who can also view them through the Company intranet - and to the business relations established by the ENAV Group.

Directors' Interests and Related-Party Transactions

Directors are invited to declare at the opening of the proceedings whether they have an interest of their own or on behalf of third parties with regard to the items on the agenda of the meeting.

The Company approves transactions with related parties in accordance with the provisions of applicable law and regulations, the provisions of its Articles of Association and the procedures adopted in this regard. ENAV's current "Procedure for related-party transactions" ("RPT Procedure") adopted in compliance with the provisions of the applicable legal and regulatory framework, was last updated, taking into account the latest regulatory changes, by ENAV's Board of Directors on 1 July 2021, having obtained the opinion of the Control, Risks and Related Parties Committee33 .

Guidelines concerning the market abuse regulation and internal dealing procedures

The Company adopts and constantly updates its controls regarding the internal management and external dissemination of documentation and information concerning the Company and its subsidiaries, with particular reference to the inside information referred to in Regulation (EU) no. 596/2014 (the "MAR Regulation") or information that is likely to become such.

The rules and principles contained in the Guidelines for the management of inside information (the "MAR Guidelines"), are aimed at ensuring compliance with the provisions of applicable market abuse laws and regulations and ensuring preservation of the maximum confidentiality of information that already qualifies as inside information or is otherwise likely to become such information, in order to prevent the selective dissemination of documentation and information concerning the Company and the Group, such as advance release to certain parties, or delayed, incomplete or otherwise inadequate dissemination.

The Company carries out periodic training and provides information on issues of market abuse and the respective sanctions.

32 These policies (published on the enav.it website and available at the following link: https://www.enav.it/node/17519) are integrated in the broader framework of regulatory instruments that the ENAV Group has adopted over the years (by way of example only, the Enterprise Risk Management System and the various management systems implemented at ENAV Group level) which - also due to the nature of the services provided by the Group - require the application of the precautionary principle.

33 This procedure identifies the rules governing the identification, approval and execution of Related Party Transactions carried out by ENAV S.p.A. - directly or through subsidiaries - in order to ensure the transparency and substantive and procedural correctness of the transactions themselves.

Management System for the Prevention of Corruption

The Management System for the Prevention of Corruption is based on the commitment of the Company and its Group to combat corruption, applying criteria of transparency and conduct based on the principle of "Zero Tolerance for Corruption". In this context, the Company is basing its work on broader compliance with the anti-corruption rules set out in national and international law and, as such, opposes and does not tolerate in any way bribery, fraudulent behaviour or illicit or irregular conduct in general that may be actively or passively committed by its employees or by third parties such as contractors, consultants, suppliers, commercial partners, agents and other individuals, legal entities and de facto entities that have relations with ENAV or its subsidiaries.

The "Policy for the Prevention of Corruption", adopted pursuant to the international standard ISO 37001:2016, and the "Management System Guidelines for Preventing and Combating Corruption" list the activities that are most exposed to the risk of corruption, based on an assessment of the risk associated with the activities carried out by the Company and its subsidiaries, and provide indications regarding the principles for the relative prevention and protection of the Group's integrity and reputation, and the sanctions applicable in the event of violation of the relative precepts.

Whistleblowing

In order to allow all Group employees and all Stakeholders to make reports, the Company has implemented a whistleblowing system for the reporting of alleged offences suitable for guaranteeing, pursuant to the reference legislation of Law 179/2017, the protection of the reporter by ensuring that the activities of analysis of the reported facts are conducted in compliance with the principles on confidentiality and anonymity prescribed by the aforementioned legislation and within a reasonable time interval.

Reports received through the various whistleblowing channels made available (IT platform, certified email, email, oral reports) are first assessed by the competent structure, which is set up for this purpose within the Internal Audit department. If they are considered relevant, they are further investigated by way of a preliminary investigation coordinated by the Internal Audit department, in cooperation with the competent structures where appropriate. The entire process (in addition to the Guidelines for the management of whistleblowing) is regulated in detail by the "Whistleblowing Regulation".

Succession Plans for Executive Directors

Efficient governance is first and foremost sound governance.

In this regard, Recommendation No. 24 of the Code states that: "In large companies, the Board of Directors shall: establish, with the support of the appointments committee, a plan for the succession of the CEO and Executive Directors, which shall at least identify the procedures to be followed in the event of early termination of office; - ascertain the existence of adequate procedures for the succession of top management".

Following the resolution passed on 27 February 2018 to adopt a Policy (the "Contingency Plan") aimed at regulating the actions to be taken in the event of the early termination of the office of the Chief Executive Officer with respect to the ordinary expiry of the term of office or his inability to perform the related functions, in order to ensure continuity in the regular management of the Company pending the identification of a new Chief Executive Officer, at its meeting of 25 January 2022 the Board of Directors, taking into account the subsequent evolutionary path of its corporate governance, proceeded to develop and define a plan for the succession of the Executive Directors taking into account considerations inherent to the structure of the corporate structure as well as the circumstance that, by law and by the Articles of Association, Directors are appointed by the Shareholders' Meeting on the basis of slates presented by the

Shareholders. The Board of Directors has therefore disciplined the actions to be taken in the event of the early termination of the office of the CEO with respect to the ordinary expiration of the mandate, or in the case of imponderable and unforeseeable events that prevent the CEO - ENAV's only executive director - from exercising his or her role.

Interventions 2022 related to the protection of legality, the fight against corruption and the protection of human rights

2022 saw a strengthening by the ENAV Group of controls on sustainability and trade compliance verticals, also thanks to an expansion of the perimeter of the Internal Audit function in the context of a broader project to strengthen controls on the subject matter, promoted also for the purpose of fighting corruption and protecting human rights, both on the first and second level of control through the creation of specific structures, the promotion of tools to guarantee compliance and an advisory activity towards internal Stakeholders for the dissemination of the culture of sustainability as a shared value, understood and integrated into daily activities by the entire corporate population.

In compliance with the principle of the Global Compact, according to which "companies undertake to combat corruption in all its forms, including extortion and bribery", the ENAV Group pursues its commitment to fight corruption, in all its forms, direct and indirect, applying the principles set out in the pillars of its Anti-Corruption Management System, which establishes zero tolerance for corruption.

In the context of the activities following the important milestone reached by ENAV in December 2021 with the certification of the ISO 37001:2016 Anti-Corruption Management System, during 2022 ENAV carried out the fraud risk assessment project, with the aim of pinpointing and assessing the areas at risk of fraud and identifying the design and improvement of the internal control system to prevent and mitigate such risks, through the identification of processes and sub-processes at risk, the definition of unambiguous metrics, the relative assessment of the inherent risk and the residual risk net of existing controls.

In general, there were several interventions on the entire body of internal Company regulations, including those on the Organisational, Management and Control Model (the "231 Model"), which all Group Companies, governed by Italian law, adopt in compliance with the provisions of Legislative Decree 231/2001. In the course of 2022, having identified the need to proceed with an update in relation to the changes introduced in Decree 231, a risk and gap analysis project was launched, taking into account the Confindustria Guidelines for the construction of 231 Models, which will lead to the updating of the Model of ENAV and the other Group Companies by the first half of 2023. In addition, a project was launched to digitise, computerise and innovate the 231 Model, which envisages actions to foster the dissemination, consultation and compliance activities of the 231 Model, including with reference to issues related to anti-corruption and the protection of legality.

In the course of 2022, the Supervisory Bodies (SB) of ENAV and the other Companies of the Group, were renewed, under Italian law, with the task of supervising the effective implementation of the 231 Model, and were all provided with a specific budget. With the appointment of the new Supervisory Bodies, the aim was to strengthen the control and supervision of 231 Models, appointing them with a composition that is either totally external or mixed with a majority of external members, as extensively reported in the Report on Corporate Governance and Ownership Structure for the year 2022, available in the appropriate section of the website www.enav.it. Closely related to Model 231 is also the ENAV Group's Code of Ethics ("Code of Ethics"), which governs the rights, duties and responsibilities that ENAV and the Group Companies assume towards the Stakeholders with whom they find themselves interacting for the performance of their activities, and is applied to corporate bodies, management, employees, external collaborators, business partners, suppliers and all those who have relations with the Company.

The adoption of certain principles of conduct and ethical standards to be observed in interactions with third parties is part of the Group's commitment, including in relation to preventing the offences referred to in Decree 231, and the prevention of corruption and fraud, and in this sense the Code of Ethics forms an integral part of Model 231. During 2022, in line with the other Companies of the ENAV Group, ENAV implemented a project to integrate the Group's Code of Ethics. The update stemmed from a need to adapt to exogenous

events impacting on the Code of Ethics, with particular regard to current geopolitical events and the various restrictive measures adopted by national and international institutions in response to the contingent conflict emergency, to this end reaffirming the need to promote a corporate culture based on full respect for life and human rights, as well as the commitment to conduct business activities in compliance with national and international rules, restrictions, provisions and guidelines on national and foreign policy and common security. The Code of Ethics also outlines further safeguards with particular regard to ESG issues, and includes the principles of diversity, protection of equal opportunities, and the protection and promotion of human rights, as provided for by the applicable internal policies.

The Code of Ethics adheres to the principles of the "Code of Conduct for Civil Servants" - aimed at ensuring respect for the constitutional duties of diligence, loyalty, impartiality and exclusive service to the care of the public interest - and recognises the following additional principles and values that are fundamental to the affirmation of the Company's mission, to which the various Stakeholders involved must refer in order to favour the good functioning, reliability and reputation of the Company: legality, safety in the provision of air navigation services, confidentiality, honesty and fairness, responsibility, equality, integrity, transparency, equity and sustainability. The rules of the Code of Ethics form an essential part of the contractual obligations of personnel, and the Group assesses from a disciplinary point of view, pursuant to the regulations in force, any conduct contrary to the principles enshrined therein, applying the sanctions that the varying seriousness of the facts may justify.

In order to enable all Group employees and Stakeholders to make reports, the Group has implemented a system for reporting alleged wrongdoing known as Whistleblowing, which was updated in the course of 2022 - in line with the provisions of Directive (EU) 2019/1937 - with the introduction of two new cases subject to possible reporting: (i) the existence of relations with persons adhering to criminal organisations of any nature or participating in violation of the principles of legality in contrast with the Code of Ethics; (ii) the violation of restrictive measures in economic and trade relations and/or sanctions adopted at national, EU and international level. The system adopted is appropriate to guarantee the protection of the whistleblower, ensuring that the activities of analysing the reported facts are conducted in compliance with the principles of confidentiality and anonymity prescribed by the reference legislation and within a reasonable time frame. The task of analysing and handling the reports received is assigned to a specially established internal committee.

In the context of the training measures envisaged by the Sustainability Plan in the areas of legality, human rights and anti-corruption, numerous training and dissemination activities were carried out in 2022 for all Group employees through corporate communication channels (newsletter, Company newspaper, e-learning courses and live sessions); the courses organised followed a risk-based approach, with specialised training tailored to individual internal structures considering the risk of committing offences under Legislative Decree 231/2001. A further in-depth training event was held on the subject of safeguards against corruption.

ENAV cooperates closely and effectively with the international organisation Transparency International. In particular, ENAV hosted and managed the organisation of Transparency International's customary annual event, which in 2022 focused on the integrity supply chain. It participated in the round table held at the end of the year on transparency, anti-corruption, ESG values and SDGs activities; and, in the context of the RIPARTIRE project aimed at increasing civic participation of young people, it took part in a session at a school in Frascati (RM), where students discussed integrity and CSR issues as pillars of their business.

Future goals Deadline
By the first half of
Updating of all ENAV Group 231 Models 2023
By the first half of
Completion of the adaptation of the whistleblowing system to Directive (EU) 2019/1937 2023
Increase in training delivered to ENAV Group employees on issues that include aspects related to
Legislative Decree 231/2001 and Code of Ethics, Anti-Bribery and Anti-Corruption, Fraud and By December 2023
Whistleblowing

Managing risks and opportunities

The ENAV Group has long adopted an Enterprise Risk Management (ERM) process aimed at identifying, assessing and monitoring risks at Group level and defining and managing actions to contain the level of risks within the propensity thresholds approved by the Board of Directors (Risk Appetite).

During 2022, the Corporate Risk Profile (CRP), the Risk Treatment Plan and the Key Risk Indicators system were updated, and risk monitoring was carried out in April and November.

Enterprise Risk Management operates in accordance with the Guidelines of the internal Control and Risk Management System (ICRMS) and to support the Control and Risks and Related Parties Committee.

The various organisational, operational and internal standard safeguards are accompanied by a constant commitment to spreading the culture of risk and risk-based management at the various levels of the Company. The manner in which they are managed is discussed in more detail in the sections addressing those specific risks.

The table below presents, for each aspect of Legislative Decree 254/2016 and with reference to CRP 2022, the related risk events, the impact for ENAV and the categories of Stakeholders involved and the main ways of managing the risks generated and suffered. The classification of impacts for ENAV follows the categories used in the Company's application of the ERM model.

TOPIC OF
LEGISLATIVE
DECREE
254/2016
RISK EVENTS POTENTIAL
IMPACT OF
THE ENAV
GROUP
STAKEHOLDERS
IMPACTED
POTENTIAL
IMPACT ON
STAKEHOLDERS
MAIN
MANAGEMENT
METHODS
Governance &
Compliance
and
fight
against
corruption
- Market abuse
- Failure to
comply with
national cyber
security
legislation
(Legislative
Decree
105/2019)
- Compliance of
systems and
infrastructure
with reference
legislation
- Management
of institutional
relations
- Changes to the
organisational
structure
- Failure to
comply with
regulations for
certification as a
Provider of air
traffic
management
services and air
navigation
services
(ATM/ANS)
- Failure to
comply with
environment
legislation
- Failure to
comply with EU
Regulation
679/2016 on
privacy
- Inadequate
positioning of
the Group in the
international
context
- Occupational
Health and
Safety (ordinary
- Strategic
- Operational
- Compliance
- Reputational
- Carriers
- Operators
- Suppliers
- Employees
- Shareholders
Carriers:
- Economic
damage
Operators:
- Economic
damage
Suppliers:
- Economic
damage
- Occupational
Health and
Safety
Employees:
- Occupational
Health and
Safety
Shareholders:
- Economic
damage
- Management
system for
preventing and
combating
corruption
- Occupational
quality, health
and safety
management
systems
- Company
policies
- System for
the delegation
of functions
- Dedicated
organisational
structures
- Specific
mitigation
measures of a
design nature
TOPIC OF
LEGISLATIVE
RISK EVENTS POTENTIAL STAKEHOLDERS
IMPACTED
POTENTIAL
IMPACT ON
MAIN
MANAGEMENT
DECREE IMPACT OF
THE ENAV
STAKEHOLDERS METHODS
254/2016 GROUP
activities)
- Fraud and
corruption
- Failure to
comply with
Legislative
Decree 50/2016
on the public
contracts code
- Failure to
comply with
Legislative
Decree
254/2016
regarding non
financial
reporting
- Uncertain
positioning of
ENAV with
respect to the
Public Contracts
Code
- Failure to
comply with
applicable
regulations for
the certification
of Training
Organisations
Environment - Compliance of
systems and
infrastructures
with reference
legislation
- Failure to
respect the
reference
legislation
concerning the
environment
- Human rights
and the
environment in
the supply chain
- Operational
- Compliance
- Reputational
- Operators
- Suppliers
- Employees
- Shareholders
Operators:
- Economic
damage
Suppliers:
- Occupational
Health and
Safety
Employees:
- Occupational
Health and
Safety
Shareholders:
- Economic
damage
-
Environmental
Management
System
- Occupational
quality, health
and safety
management
systems
- Company
policies
- System for
the delegation
of functions
- Dedicated
organisational
structures
TOPIC OF
LEGISLATIVE
DECREE
254/2016
RISK EVENTS POTENTIAL
IMPACT OF
THE ENAV
GROUP
STAKEHOLDERS
IMPACTED
POTENTIAL
IMPACT ON
STAKEHOLDERS
MAIN
MANAGEMENT
METHODS
- Specific
mitigation
measures of a
design nature
Respect
for
human rights
- Failure to
respect Reg. EU
679/2016
General Data
Protection
Regulation
(GDPR)
- Human rights
and the
environment in
the supply chain
- Diversity
- Compliance
- Reputational
- Suppliers
- Employees
- Shareholders
Suppliers:
- Occupational
Health and
Safety
Employees:
- Occupational
Health and
Safety
Shareholders:
- Economic
damage
- Quality
management
systems
- Company
policies
- Dedicated
organisational
structures
- Specific
mitigation
measures of a
design nature
Pertinent
to
personnel
- Risk of disputes
- Safety of
personnel
working in
Countries at risk
(travel security)
- Occupational
Health and
Safety for
contract work
- Suitability of
human capital
- Staff turnover
- Occupational
safety (H&S) for
ordinary
activities
- Labour disputes
- Operational
- Compliance
- Reputational
- Carriers
- Operators
- Suppliers
- Employees
- Shareholders
Carriers:
- Economic
damage
Operators:
- Economic
damage
Suppliers:
- Economic
damage
- Occupational
Health and
Safety
Employees:
- Occupational
Health and
Safety
Shareholders:
- Economic
damage
- Occupational
quality, health
and safety
management
systems
- Company
policies
- Dedicated
organisational
structures
- Specific
mitigation
measures of a
design nature
TOPIC OF
LEGISLATIVE
DECREE
254/2016
RISK EVENTS POTENTIAL
IMPACT OF
THE ENAV
GROUP
STAKEHOLDERS
IMPACTED
POTENTIAL
IMPACT ON
STAKEHOLDERS
MAIN
MANAGEMENT
METHODS
Social - Aeronautical
accident in
relation to ATM
contribution
- Group
reputation
- Continuity of
core services
- Information
security
- Physical safety
- Aeronautical
accident of the
air fleet owned
by ENAV
- Discontinuity of
the
administrative
managerial
services
- Operational
- Reputational
- Compliance
- Carriers
- Operators
- Institutions
- Employees
- Shareholders
Carriers:
- Economic
damage
Operators:
- Economic
damage
Institutions:
- Reputational
damage
Employees:
- Occupational
Health and
Safety
Shareholders:
- Economic
damage
- Occupational
quality, health
and safety
management
systems
- Company
policies
- Dedicated
organisational
structures
- Specific
mitigation
measures of a
design nature
Climate
change
- Climate change
(emerging risk)
- Operational
- Strategic
- Carriers
- Operators
- Shareholders
Carriers:
- Economic
damage
Operators:
- Economic
damage
Shareholders:
- Economic
damage
- Specific
mitigation
measures of a
design nature
- Operating
procedures

Risks associated with climate change34

Types of risks and impacts All possible direct impacts for ENAV related to the effects of climate change
translate in the long term into potential interruptions/degradations in the
provision of services due to damage to infrastructures or technological assets
and reduction of traffic flow also due to the reduction of airport capacity and,
therefore, into potential lost revenues and/or increases in operating costs.
The impacts of the phenomena determined by climate change on air traffic
Stakeholders have been identified and studied over the years on an
international level. In particular, the EUROCONTROL document "Climate change
risks for European aviation" (6 September 2021) identifies five main types of
weather phenomena that could potentially impact aviation:
1. PRECIPITATION
Events related to heavy rainfall may require greater safety distances between
aircraft,
directly
impacting
airport
capacity.
Furthermore,
airport

34 In compliance with the European common enforcement priorities for 2022 annual financial reports, issued by ESMA on 28 October 2022.

infrastructures, as well as electrical equipment, can be exposed to a risk of
flooding.
2. TEMPERATURE
Rising temperatures can cause impacts on infrastructure, with associated
energy costs, as well as impacts on engine performance and aircraft
aerodynamics, with potential impacts on flight procedures and noise footprints
in the areas surrounding airports.
3. RISING SEA LEVEL AND OVERFLOWING OF RIVERS
Potential impacts on airports located on the coastal strip or near rivers, which
are exposed to the risk of flooding and inundation.
4. WIND
Risk of strong cross winds impacting flight safety. This could make it necessary
to change the flight procedures and redesign the air space, with the possible
additional environmental risk due to the redistribution of the acoustic impact
around airports.
5. EXTREME EVENTS
Potential impacts in terms of flight delays. Furthermore, European continental
areas could experience larger convective systems that could potentially involve
multiple major airports in the same region. This could reduce the choice of
alternating airports with a consequent decrease in service capacity.
In August 2022, ENAV set up a special Working Group to assess in detail the
effects of climate change in the specific locations where it provides its services
in Italy and in particular at airports. The Working Group worked with the
specialist support of external experts to assess the possible impacts of climate
change on ENAV's core business activities over two distinct time horizons (2030
and 2050).
The study, which is currently being finalised, made it possible to assess the
possible impacts of climate change on ENAV's core business activities over two
different time horizons and two different climate scenarios used by the
Intergovernmental Panel on Climate Change (IPCC). The first scenario (SSP8.5),
the most pessimistic, assumes, by 2100, atmospheric CO2 concentrations will
triple or quadruple (840/1120 ppm) compared to pre-industrial levels (280
ppm). This scenario is energy-intensive with total consumption continuing to
grow over the century to well over 3 times current levels.
The second (SSP4.5) assumes the implementation of certain initiatives such as
the use of a range of technologies and strategies to reduce greenhouse gas
emissions. A stabilisation scenario has been proposed: CO2 emissions will peak
around mid-century and by 2070 fall below current levels. The atmospheric
concentration of carbon dioxide will stabilise by the end of the century at about
twice (520 ppm) pre-industrial levels.
Although the study is currently being finalised, it is nevertheless possible to
anticipate here that:

with regard to extreme precipitation, a progressive intensification of the
phenomenon is expected in the long term (2050), which is expected to
affect an increasing number of airports over time;

as far as wind is concerned, there do not seem to be any critical issues, as
the forecasts of the above-mentioned scenarios are oriented towards a
decrease in the average wind intensity (consequently, the crosswind
component should decrease proportionally);
temperature is expected to rise by 1-1.5o C (2030) and 2-2.5o C (2050)

depending on the scenarios, which will affect an increasing number of
airports over time;

with regard to the rise in sea levels, the flood risk of infrastructure located
in coastal areas remains virtually unchanged.
The results of the analyses conducted will lay the foundations for monitoring the
phenomena under study over time. This can be achieved by regularly updating
the climate scenario analysis (e.g., every 2-3 years) in order to process an
adequate amount of new data (business and scenario), so as to update the
quantification of the operational and financial impacts of climate risks.
Any further mitigation or adaptation actions will be taken downstream of the
monitoring, as a possible consequence of the increased risk level.
In the long run, ENAV's ability to ensure the pursuit of its business objectives,
first and foremost by guaranteeing the continuity of its service provision, is
undoubtedly interdependent on the resilience to the effects of climate change
of the entire air transport system. In particular, the airport system involves
complex interaction between the various actors (airport operators, carriers,
ground transport and road infrastructure operators, utilities, etc.), therefore
long-term mitigation could in some cases require a coordinated and shared
approach among all the involved actors in order to reduce the overall impact on
sector business activities.
Adaptation
and
management
ENAV is constantly engaged in guaranteeing the safety and punctuality of
method millions of passengers who fly in Italian airspace, ensuring the continuous
provision of air navigation services. The operational safety level of the air
navigation services is in fact an essential priority for ENAV that, in pursuing its
institutional and strategic objectives, favours the achievement of the
paramount objectives of safety. The Group has defined and regularly tests
specific Business Continuity and Disaster Recovery plans on the basis of an in
depth Business Impact Analysis, defining the appropriate procedures to be
applied in the event of events involving a significant deterioration or
interruption of services, in order to preserve continuity in the various possible
emergency scenarios. ENAV guarantees the necessary levels of the continuous
availability of operational personnel. Personnel periodically receive training and
instruction to maintain their required professional qualifications. The necessary
levels of availability of the technological component are also guaranteed
through specific functional redundancies and by means of an extended
maintenance plan to which all the systems and equipment that support the air
navigation services are subjected. The service level of the technological
component is also supported by specific investment plans that aim to increase
the performance of systems and equipment in terms of reliability, availability,
safety and efficiency.

Remuneration policies

The remuneration policy of the ENAV Group differs based on the position held in the organisation, without any discrimination on the grounds of age, gender, disability, race, ethnicity, origin, religion or other.

The remuneration policy is defined through a detailed preliminary activity performed by the Remuneration and Appointments Committee, the majority of which is composed of independent bodies, with the collaboration of an external advisor and the contribution of the Sustainability Committee and/or other internal units. The proposal is submitted to the Board of Directors, which, pursuant to Legislative Decree 49/2019, proposes it to the Shareholders' Meeting, which resolves by binding vote. Market practices and suggestions from proxy advisors are analysed as part of the investigative activities.

As far as the Chief Executive Officer and Managers with Strategic Responsibilities are concerned, the remuneration policy, as defined in section 1 of the Report on Remuneration Policy and Compensation Paid (approved with a binding vote by the Shareholders' Meeting of 21 April 2022) provides for the recognition of a fixed remuneration component as well as a short-term and long-term variable remuneration component, the latter anchored to objectives of an economic-financial and ESG nature, with a view to contributing to the achievement of the results of the corporate strategy and the pursuit of long-term interests, in a logic of corporate sustainability.

The long-term variable incentives system is based on a Performance Share Plan approved by the 2020 Shareholders' Meeting, based on three cycles of rolling assignment with a three-year vesting period and annual assignment.

The Remuneration Policy provides for severance pay for the Chief Executive Officer in the event of nonrenewal of the employment relationship or early termination of office. In particular, in the event of nonrenewal at the end of the term of office, the variable short-term incentive payment pro rata temporis will be granted to the CEO.

The provisions on the long-term variable incentive pursuant to the 2020-2022 LTI Plan and respective Implementing Rules of the 2020-2022 LTI Plan shall also apply. In the case of early termination of office without just cause, in accordance with the recommendations of the Corporate Governance Code, the amount due to the Chief Executive Officer as severance pay is equal to two years of fixed remuneration pursuant to Article 2389(1) and (3) of the Italian Civil Code, plus a pro-rated share of the long-term variable incentive already vested at the time of termination. The incentive is only paid for the years in which the performance target was achieved, and its amount is determined by the Board of Directors subject to the assessment of the actual performance achieved and recalculated only for the years considered.

With regard to the short-term incentive, the Board of Directors shall, on a case-by-case basis, determine the amounts that may have vested and whether the required conditions for the associated payment have been met, taking due account of the period of the year in which the termination occurs and other contingent circumstances.

For Managers with Strategic Responsibilities, in the event of termination of the employment relationship with the Company, the conditions provided for in the relevant collective bargaining agreement apply, without prejudice to any existing individual agreements.

With regard to the variable components of remuneration paid to the Chief Executive Officer, and the other Managers with Strategic Responsibilities, the Remuneration Policy envisages a claw-back clause covering both negligence and loss and material error for a period of 36 months after the approval of the financial statements containing the irregularities that triggered the clause. This provision is in line with the recommendations of the Corporate Governance Committee.

In relation to Group management and supervisory personnel, the remuneration policy, which has been consolidated over the years, provides for payment of a short-term variable component anchored to a topdown Management By Objectives (MBO) system: objectives are established in accordance with the strategic guidelines and expressed in terms of activities/pillars based on the various responsibility levels. Individual objectives are linked to economic-financial dimensions, investment, technological innovation also aimed at environmental and social aspects.

A selected number of management roles, chosen by the CEO, are also assigned long-term targets in line with the Share Performance Plan created for top management.

In relation to Middle managers, the variable remuneration policy provides for the allocation of individual targets only to a small sample of the population in accordance with the position held and the responsibilities assigned, these objectives are connected to the projects assigned to the responsible management population, with the indicated top-down logic.

The related awards are correlated with the reference organisational cluster, with a logic of increasing complexity of the office held.

With regard to "non-executive" personnel, the performance assessment process is launched annually in order to acquire information concerning the performance and competences of the personnel who have worked with the Company for more than 6 months in the year.

The process involves the definition by the competent organisational structures of lists of all the Group's resources (ENAV, Techno Sky and IDS), which meet the necessary requirements to become part of the perimeter of persons to be assessed. The employees concerned and their evaluators are selected in accordance with their possession of specific individual qualities. Subsequently, the technical skills and performance evaluation and validation process is launched and managed by means of a specific tool. Following the evaluations expressed, specific "calibration" sessions are promoted with first and second level supervisors, in order to make the evaluation metrics as consistent and objective as possible, as well as to identify the possibilities of intervention on individual resources from a managerial (training, job rotation, assessment) or economic point of view.

SHORT-TERM
Weighting
EBITDA 35%
Net profit 15%
Operating performance 20%
Revenue from non-regulated
activities
15%
Sustainability indicator* 15%
* Consisting of 2 independent project objectives
with on/off type achievement criterion

Managers with Strategic

Tax management

In line with the principles of transparency and legality set out in the Code of Ethics, the ENAV Group's approach to taxation is geared towards full compliance with tax regulations. Although there is no formalisation of a tax strategy policy, the ENAV Group, whose main activity is in Italy, also correctly fulfils its tax obligations through a well-defined organisation and procedures under Law 262 that define activities, roles and responsibilities.

Any controversial regulatory aspects are addressed and discussed with external consultants and, in some cases, brought to the attention of the tax authorities by means of petitions for appeal.

The Group is committed to complying with tax regulations by means of:

  • appropriately managing the tax burden related to Group activities.
  • staying up-to-date with the national and international regulations concerning its own area of activity.
  • maintaining good relations with tax authorities based on absolute transparency and collaboration.
  • studying transfer pricing is necessary for the definition of intercompany contracts with companies present in countries other than Italy.

Tax returns are subject to audit by the tax consultants and signing by the external auditors.

The Financial Reporting Officer in charge of preparing the Company's documents participates in tax-related decisions both on a strategic level as well as on an operational level, and is responsible for monitoring the tax risk management activities and assesses the suitability of the organisational structure dedicated to tax issues.

In 2022, tax risks were the subject of a new comprehensive risk assessment project for the purpose of the 231 Model update planned for 2023.

Tax offences were the subject of analysis in 2020 as part of the updating of the 231 Organisational Model, which also covered tax risks. The analysis carried out for the purpose of adjustments did not reveal any organisational criticalities in the management of tax risks within the Group.

Responsible supplier management

For the ENAV Group, sustainability also means creating a relationship with its suppliers based on collaboration and complete transparency of information and also due to the fact that a Company's relationship is also linked to all its collaborations along the value chain.

For these reasons, given that ENAV's and Techno Sky's awarding procedures are subject to the Public Contracts Code35, it should be noted that, in view of the specific provisions of Legislative Decree 18 April 2016 no. 50 as amended, the Companies started an initial process of analysis on some suppliers in order to 'test' their relative conduct in the ESG sphere. Specifically, an experimental process of analysis was started in relation to a number of suppliers and more significantly on:

  • suppliers that represent the strategic supply line for the Group, also in light of the amounts contracted with them (core suppliers).
  • suppliers that may be considered more "at risk" in this respect on the basis of their ATECO (economic activity) category.

In this context, with the aim of analysing the "conduct" of the aforementioned suppliers in the ESG sphere, a specific IT platform was adopted at an experimental level, dedicated to the collection of specific data and information in order to "test", with reference to the aforementioned suppliers, the relative "level of sensitivity" in this sphere in light of specific automated drivers.

With regard to the above, it is hereby reported that, during 2022, the concrete analyses carried out recorded, in relation to the panel of "tested" suppliers, a satisfactory outcome, also in consideration of the fact that more than 50% of the suppliers surveyed provided appropriate feedback through the aforementioned platform.

In view of all this, it can therefore be stated that an effective channel of information exchange has most certainly been established that can help to increase the commitment to ESG on the part of ENAV and Techno Sky and their suppliers also through a future shared path of improvement.

Within ENAV's ERP Oracle Application system, there is also a supplier performance evaluation process, governed by a special procedure, where suppliers are evaluated by the Managers of the relevant contracts/PM on the basis of the following criteria:

  • level of compliance of performance with contractual requirements.
  • full compliance of the contractual services performed with the SLAs foreseen in the contract.

The individual performance indicators of the supplier make it possible to obtain, using the ERP system, an overall vendor rating index (VRI).

The problems identified and serious breaches (including violation by th1818e contractor concerning the fight against Mafia-type crime, regulations on occupational health and safety pursuant to Legislative Decree 81/2008 or environmental regulations pursuant to Legislative Decree 152/2006) must be communicated by sending the "Critical issues/blocking events form" to the system (ERP).

The procedure for the assessment of Techno Sky suppliers (SAP System) requires, in line with ENAV's process, a supplier rating that, if negative after the detection of critical issues, is communicated to ENAV in order to adopt the measures described in the above procedure.

35 It should be noted that for the subsidiary D-Flight, the Public Contracts Code is applied to the contract awarding procedures

The analysis of the ratings found by the performers/PMs and processed by the system did not reveal any critical issues in the environmental and social fields.

Parallel to the development of these assessment systems, a "Code of Conduct for Suppliers" has been drawn up, acceptance of which is mandatory for all ENAV and Techno Sky suppliers.

It should be noted that, at the Procurement level, ENAV continued the process aimed at including, in the context of specific contracts relating to labour-intensive contracts, the obligation of suppliers to undergo third-party audits in relation to compliance with specific contractual provisions aimed at ensuring compliance with environmental and social requirements related to the particular services entrusted. To this end, on a practical level, two audits were carried out by a third-party company appointed for this purpose on a category considered to be particularly at risk according to its ATECO code (cleaning services).

In addition, depending on the type of contract, there are specific provisions in the Contracts and their annexes that refer to explicit regulations in the area of respect for Human Rights, with particular reference to the prohibition of the exploitation of child labour and compliance with any similar regulations on the matter.

In line with what has been implemented by the Parent Company, in the majority of its orders and contracts with Italian suppliers IDS Air Nav includes clauses regarding the principles contained in the Code of Ethics and in Legislative Decree 231/2001. It should be noted that IDS Air Nav includes clauses in its contracts, similar to ENAV, referring to respect for human rights.

Lastly, it should be noted that, over the last few years, ENAV, in relation to its tenders, has paid increasing attention to environmental sustainability; this choice is based on ENAV's desire to reduce the environmental impact of the services that are purchased and the works that are carried out, in accordance with the provisions of Legislative Decree 50/2016, and in particular Article 34 thereof.

FURTHER INFORMATION ON THE GROUP'S ACTIVITIES, VALUE CHAIN AND BUSINESS RELATIONS

Techno Sky is active in the following main areas:

  • ensure the Business Continuity of ENAV.
  • perform overall "System Integrator" activities both for the Parent Company ENAV S.p.A. and within the so-called Third Market.

Techno Sky's Suppliers mainly consist of companies supplying goods, services and works that accompany the Company from self-functioning activities to the 'core' activities aimed at maintaining the systems used by the Parent Company for the air traffic control service, in order to ensure its business continuity (by way of example, the supply of hardware components necessary for the operation of the technological infrastructure, the purchase and maintenance of electronic equipment, etc.). With reference to the selection operations of Suppliers, Techno Sky is required to apply Legislative Decree 50/2016, as amended. (the so-called 'Public Contracts Code'). On the other hand, with regard to the selection of Suppliers, who shall support Techno Sky in the activities entrusted to it with reference to the Third-Party Market, the latter operates in accordance with the aforementioned Legislative Decree and, therefore, according to the logic of transparency and competitiveness with reference to the specific procurement context.

IDS AirNav is a Company that develops technology solutions for the air navigation market, both nationally and internationally. The target market in which IDS AirNav operates consists of civil and military ANSPs (Air Navigation Service Providers), civil aviation authorities and airport operators.

IDS AirNav works along two axes:

  • the development of COTS (Commercial Off The Shelf) software products;
  • the development of turnkey technical solutions, consisting of different software products that are suitably assembled and configured to suit specific customer needs.

The products developed can be classified into the following categories:

  • Aeronautical Information Management, i.e., products for the management of aeronautical data and the exchange of these data between the various Stakeholders (airport operators, ANSPs, civil aviation authorities)
  • Air Traffic Flow Management, i.e., products for managing traffic flows and identifying any imbalances between air traffic volumes and control capacity, in response to which action must be taken (flight delays, ATCO staffing, etc.)
  • Aviation Revenue Management System, i.e. the product for calculating and managing invoices on services provided by ANSPs

While COTS products are developed on in-house orders (investment or maintenance), customer solutions are developed within the framework of revenue-generating orders that generally involve the provision of the following services:

  • Requirements analysis, i.e. analysis of specific customer needs;
  • Designing the technical solution needed to meet the requirements;
  • Carrying out product configuration activities, as stable in the design phase;
  • Operational testing and transition at customer sites of supplied solutions.

Obviously, there is a close interconnection between products and the implementation of technical solutions for customers. For example, if the requirements analysis reveals gaps in COTS products, development activities on those products are planned and conducted in order to compose the complete solution required by the customer. When a given technical solution enters into operational use at a customer's premises, a maintenance contract is typically activated, which includes the provision of product updates to the customer and customer service.

In carrying out COTS product development activities and customer solutions, IDS AirNav uses external suppliers for software development services and for the provision of third-party hardware and software on which the products and solutions offered to customers are based.

ENAV Asia Pacific provides aviation consultancy services to institutional customers in Malaysia (Ministry of Transport) and Taiwan (ANSP) and provides FPDAM Flight Procedure Design and Management) maintenance services. The services are provided through the technical support of ENAV S.p.A. and IDS AirNav, formalised in the intercompany agreement, in addition to the project management activities provided by personnel seconded to Malaysia. As far as the supply chain is concerned, ENAV Asia Pacific continues to make use of ENAV Group's suppliers - mainly for consultancy activities relating to aspects of Malaysian corporate and tax compliance - and/or verified through a formal request for details (e.g., verification through the SSM - Companies Commission of Malaysia).

Security management

The issue of Security, understood in its broadest sense, is one of the central elements in the ENAV Group's activities, both as a critical infrastructure and an essential service operator, with a mission defined by law and directed to the protection of primary interests of the legal system such as the safeguarding of human life in flight and on the ground, and safeguarding the protective needs of personnel, infrastructures, systems, data, information and networks in its purview.

The Group Security Policy summarises the ENAV Group's commitment in its entirety to the pursuit of protection objectives, in the context of the mission and obligations of the Group and of each of its component Companies.

This commitment is in line with developments in current as well as newly introduced legislation, in view of which the Group has substantially strengthened its security structures, with a more significant presence in the areas of security culture development, security by design, monitoring and response capability.

These undertakings, defined and formalised, have found correspondence, on the one hand, in specific investment measures to increase security levels, and on the other hand, in the launch of a programme to strengthen the Security organisation structure, correlated with a specialised training plan for personnel, to enrich skills, knowledge and abilities in a plan to increase the Group's internal value.

The residual effects of the pandemic and those related to the Russia-Ukraine conflict have led to the adoption of specific reinforcement actions, in full awareness of the volatility of the risk scenario, which has a more than appreciable impact on the dimension of prevention, containment and response to security events, in their various manifestations.

Fundamental in this framework are:

  • the involvement of all Group personnel in training, practice and competence-building activities, including in non-traditional ways.
  • the definition of specific security requirements, which characterise the principle of "security by design", and the verification of their compliance throughout the life cycle of the systems is not only an element of compliance, but also an operational necessity, in order to keep the level of service capability and continuity of operations constantly updated.
  • the monitoring of security levels, the analysis of potential threat matrices, the management of events and the adoption of countermeasures to vulnerability detection and resolution actions, with the use of two monitoring and response structures, the Security Operation Centre for physical security and the Security Operation Centre for information security, which also functions as a certified and accredited Computer Emergency Response Team.

In the framework described above, it is clear that security is an integral and fundamental part of the ENAV Group's mission, which is reflected - at different levels - in all the relations that the Group's Companies have with national, European and international institutions as well as with users, customers and suppliers.

With particular regard to the latter, because of the complexity and delicacy of the supply chain today, a structured management process of the principles of supply chain security is operative, aimed at determining the conscious involvement of partners in works, supplies and services, as they too are an integral part of the duty of protection, imposed by law and ethically due for the safeguarding of the fundamental values entrusted to ENAV S.p.A. and to a collateral extent to the other Group Companies.

Within the framework of the strong focus on fundamental rights, the duty of protection that Group Companies have towards expatriate staff is well in place, through the strengthening of preventive measures and during missions; as well as the increase in training tools for due respect for the cultures and sensitivities of the countries visited.

Annex 1 – Non-financial indicators

PLANET

Table 1. Consumption of electricity and fuels for the operation of offices and other facilities (e.g., Control Towers) and of the car and aircraft fleets (by renewable/non-renewable) [GRI 302-1].

Supplies u.m. 2022 2021 2020
Electricity 241,998.59 243,865.66 241,131.29
from renewable sources 218,329.67 56,307.74 1,095.28
Of which self-produced and consumed 1,120.27 1,031.71 1,095.28
Of which from GO sources 217,209.40 55,276.93 0
From non-renewable sources 23,668.92 187,557.92 240,036
Fuels for offices and other facilities 26,592.85 30,184.18 24,509.94
Diesel GJ 3,696.66 5,751.02 3,787.48
Natural gas 22,896.19 24,433.16 20,722.46
Fuels for car fleet – Company cars 5,714.26 4,119.33 3,743.45
Diesel 2,178.14 3,019.84 3,046.88
Petrol 3,536.12 1,099.49 696.57
CNG 0 0 0
LPG 0 0 0
Fuels for car fleet – Mixed-use cars 4,206.89 4,119.25 3,891.36
Diesel 1,583.19 3,136.96 2,842.35
Petrol 2,600.68 971.42 954.70
CNG 20.92 10.87 90.36
LPG 2.09 0 3.94
Fuels for air fleet 19,807.16 20,578.98 19,691.80
Jet fuel 19,807.16 20,578.98 19,691.80
Total energy consumed 298,319.75 302,867.40 292,967.84

In accordance with the provisions of Article 51, paragraph 4(a), of the Consolidated Income Tax Law, fuel consumption relating to Company cars for mixed business and personal use is measured at 70% of the total.

The self-produced electricity fed into the grid in 2022 was 63.65 GJ, in 2021 263.78 GJ and in 2020 382.45 GJ.

Table 2. Energy intensity [GRI 302-3]

Energy intensity within the organisation
u.m. 2022 2021 2020
Energy intensity GJ/Number of full-time employees 71.8 74.4 71.5

Table 3. Emissions from the consumption of electricity, fuel for the operation of offices and facilities (e.g. control towers), the car and aircraft fleet and emissions from the use of refrigerant gases. [GRI 305-1 and 305-2]

Emissions u.m. 2022 2021 2020
Location based electricity 17,383 17,572 18,422
Market based electricity 3,005 23,891 31,064
Fuel for offices and other facilities 1,408.30 1,621.95 1,309.52
Diesel 247.62 378.38 253.1
Natural gas 1,160.68 1,243.56 1,056.42
Fuel for car fleet – Company cars 369.08 268.87 247.96
Diesel 145.91 198.69 203.61
Petrol 223.17 70.19 44.35
CNG 0 0 0
LPG t CO₂e 0 0 0
Fuels for car fleet – mixed-use cars 271.37 268.96 255.57
Diesel 106.05 206.39 189.94
Petrol 164.14 62.01 60.78
CNG 1.06 0.55 4.62
LPG 0.12 0 0.23
Fuels for air fleet 1,365.20 1,416.65 1,355.57
Jet fuel 1,365.20 1,416.65 1,355.57
Refrigerant gases 886.32 1,204.89 368.56
Total emissions (location based) 21,683.67 22,353.02 21,959.95
Total emissions (market based) 7,304.92 28,672.54 34,601.18

Scope 2 emissions inherent to the consumption of electricity are calculated according to the Location Based methodology, using the emission factors published by ISPRA 2021 and according to the market-based approach using the emission factors published by AIB – European Residual Mixes 2021.

In accordance with the provisions of Article 51, paragraph 4(a), of the Consolidated Income Tax Law, emissions relating to Company cars for mixed business and personal use is measured at 70% of the total. The method used to calculate emissions from fuels uses the emission factors published in 2022 by the Department for Environment Food & Rural Affairs.

It should be noted that in 2022, the methodology for calculating emissions from the consumption of electricity from Guarantees of Origin (GO) was updated according to the Market-Based methodology. This methodology was also applied to the 2021 figure, in order to report a value as accurate and comparable to the current reporting year as possible. The previously reported 2021 figure was 24,464 tCO2e

Table 4. Other indirect greenhouse gas (GHG) emissions (Scope 3) [GRI 305-3]

Emissions u.m. 2022 2021 2020
Fuel- and Energy
Related Activities
1,319.17 5,568.92 4,483.57
Employee
commuting
7,289.93 7,086.22 6,489.77
Capital goods 31,902.66 28,601.97 29,601.13
Purchased goods
and services
t CO₂e 12,513.23 12,134.49 10,665.64
Others 85.90 161.39 116.73
Business Travel 1,257.11 443.19 332.57
Scope 3 total 54,368.00 53,996.17 51,689.42

The method used to calculate emissions uses the emission factors of the Department for Environment Food & Rural Affairs (DEFRA) 2021 e 2022, Ecoinvent 3.8 e Base Carbon v.19.

Within the category "Others", data for the categories "Waste" and "Upstream transportation and distribution" are included and merged as they each have a weight of 0.2% of total emissions.

It should be noted that in 2022, the methodology for calculating the emissions generated by electricity consumption from Guarantees of Origin (GO) was updated for the calculation of the Fuel- and Energy-Related Activities category. This methodology was also applied to the 2021 figure in order to report as accurate a value as possible and make it comparable to the current reporting year. The previously reported 2021 figure was 6,994.05 tCO2e.

Table 5. Intensity of greenhouse gas (GHG) emissions [GRI 305-4].

Intensity of emissions (Scope 1 + Scope 2)
u.m. 2022 2021 2020
Intensity of emissions tCO2eq Location based/full
time employees
5.22 5.49 5.36
Intensity of emissions tCO2eq Market based/full-time
employees
1.76 7.04 8.45
Intensity of other indirect emissions (Scope 3)
u.m. 2022 2021 2020
Intensity of emissions tCO2eq Scope 3/full-time
employees
13.08 13.26 12.62

Table 6. Greenhouse gas (GHG) emissions avoided through electricity production from existing photovoltaic systems [GRI 305-5].

Reduction of emissions u.m. 2022 2021 2020
Reduction of Co₂e (Scope2) t CO₂e 85 94 113

The methodology used for the reporting year 2021 and 2022 for emission reduction calculations involves the use of the ISPRA 2021 emission factors. The methodology used for the 2020 reporting year involves the use of emission factors published in 2020 by the Department for Environment Food & Rural Affairs (DEFRA).

Table 7. Waste generated [GRI 306-3]

2022 2021 2020
Type of
waste
u.m Sent for
recyclin
g
Sent for
disposa
l
Waste
generate
d
Sent for
recyclin
g
Sent for
disposa
l
Waste
generate
d
Sent for
recyclin
g
Sent for
disposa
l
Waste
generate
d
Batteries
from
accumulator
s
39.80 0 39.80 52.35 0 52.35 37.37 0 37.37
Waste
engine oil,
gear oil and
lubricating
oils
4.77 0 4.77 5.00 0 5.00 5.82 0 5.82
Waste from
electrical
and
electronic
equipment
48.46 0.13 48.59 103.78 0 103.78 35.99 0.01 36
Other
municipal
waste (septic
tank sludge,
bulky waste)
t 24.64 54.35 78.99 18.77 111.11 129.88 39.57 62.27 101.84
Packaging
(including
municipal
waste from
separate
collection)
21.56 0 21.56 29.20 0 29.20 19.28 0 19.28
Metals
(including
their alloys)
57.30 0 57.30 24.26 0 24.26 9.07 0 9.07
Other waste 35.30 4.43 39.73 21.03 2.94 23.97 37.31 5.50 42.81
TOTAL
WASTE
231.83 58.91 290.74 254.39 114.05 368.44 184.41 67.78 252.19

Table 8. Waste for recovery and waste for disposal [GRI 306-4; 306-5].

Hazardous waste u.m. 2022 2021 2020
Landfill disposal t 1.46 1.65 1.17
Sent for recycling 57.46 69.27 54.47
TOTAL WASTE 58.92 70.92 55.64
Non-hazardous waste u.m. 2022 2021 2020
Landfill disposal t 57.45 112.40 66.61
Sent for recycling 174.37 185.12 129.94

Note: All waste is managed at external sites

Table 9. Investments in infrastructures.

Collision 2022 2021 2020
Infrastructures 87,763 76,068 77,493
a) Implementation and maintenance of operational
technology infrastructures
€000 50,092 44,418 39,760
b) Upgrading the ATM platform with new operational
concepts
15,459 14,075 24,566
c) Infrastructures and systems 13,152 12,333 7,639
d) Management information systems 9,060 5,242 5,528

Note: 2022 CAPEX of € 97.8 million

Table 10. Reductions in routes and related impact the Italian Flight Efficiency Plan (FEP) project, highlighting the result since the beginning of the FEP project.

Main results achieved u.m. 2022 2021 2020 Trend 2016-2022
Reduction of routes km -21,750,500 -12,710,000 -7,237,000 - 77,867,335
Reduction of fuel used kg -79,500,000 -52,789,000 -29,623,000 -294,968,500
Reduction of CO₂ emissions kg CO₂ - 250,425,000 -166,285,350 -93,312,450 -929,150,775

Table 11. Number of flight hours carried out by the air fleet broken down by domestic and foreign contracts.

Flight hours u.m. 2022 2021 2020
Domestic hours 943.60 1,048.93 967.30
Abroad 419.01 321.60 368.84
Saudi Arabia 0 0 0
Kenya 0 0 0
Eritrea 0 0 0
Uganda 61.09 14.58 28.75
BLUE GNSS 0 0 0
Albania 19.00 13.67 4.58
Lithuania Hours 18.25 20.75 9.17
United Arab Emirates 0 0 0
ONDA (Morocco) 0 0 0
Qatar 84.83 33.25 0
Phoenic (Romania) 0 157.34 216.50
INEA 0 0 0
Cyprus 16.08 0 0
Croatia 108.84 115.26 110.84
Total 1,362.61 1,370.53 1,337.14

Table 12. Average response time for extraordinary interventions thanks to the Flight Inspection and Validation service.

Average response time for extraordinary interventions u.m. 2022 2021 2020
Average response time Hours 24 24 24

STAKEHOLDERS

Table 13. Customer relations: Average system availability. (Scope: Techno Sky)

Average system availability u.m. 2022 2021 2020
Percentage of average system availability % 99.99 99.98 99.97

Table 14. Customer relations: Percentage of anomaly resolution on first attempt. (Scope: Techno Sky)

Resolution of anomalies on first attempt u.m. 2022 2021 2020
Percentage of anomaly resolution on first attempt % 87% 90.00 91.00

Table 15. Customer relations: Hours for repair and restoration. (Scope: Techno Sky)

Repair and restoration u.m. 2022 2021 2020
Average repair and restoration times Minutes 33.52 33.20 33.57

Table 16. Processing days for measurement confirmation. (Scope: Techno Sky)

Processing for measurement confirmation 2022 2021 2020
Average
processing
time
for
measurement
confirmation of weather sensors
Days 15.58 14.58 14.87

Table 17. Approach to Stakeholder Engagement [GRI 2-29].

Degree of Stakeholder
involvement
u.m. 2022 2021 2020
Stakeholder Engagement
initiatives
18 one-to-one meetings
with airline companies.
Three plenary meetings
extended, for the topics
covered, to all customers
of our services.
12 meetings (10 web and 2 in
person) for the updates.
Web meeting for updates.
Cooperation agreements for
structure in relationships and
advanced involvement
Number of Stakeholders
involved
No. Variable number
depending on events.
Invitations to plenary
meetings extended to
more than 40 companies
on average. Output of
meetings made available to
all
A variable number depending
on the initiatives. In the case
of ramp-up meetings,
numerous groups of pilots
and airlines
A variable number depending
on the initiative with
information forwarded to the
majority of the AUs
Other Direct involvement of
customers in line with the
contents of signed
cooperation agreements
and memoranda of
understanding.
All the activities specified in
the cooperation agreements
for relations with customers
of ATS services. Direct
dialogue with the operational
line in the case of ramp-ups.
Participation in the initiatives
defined in the cooperation
agreements. Sharing of
feedback to improve the
service.

PEOPLE

Table 18. Total number of employees by Group Company. [GRI 2-7]

Total number of employees in the Group u.m. 2022 2021 2020
ENAV 3,306 3,295 3,330
Techno SKY 721 658 665
IDS AirNav No. 158 152 150
ENAV Asia Pacific 0 1 2
ENAV North Atlantic 0 0 0
Total 4,185 4,106 4,147

Note: It should be noted that in D-Flight, there are 7 seconded employees (4 ENAV, 3 IDS AirNav), and 3 seconded from Leonardo and Telespazio.

Table 19. Total number of employees by contract type, geographical area (where they are employed), and gender. [GRI 2-7]
-------------------------------------------------------------------------------------------------------------------------- -- -- -- -- -- -- -- -- --
Employees 2022 2021 2020
(headcount) u.m. Male Female Total Male Female Total Male Female Total
Fixed-term contract 2 3 5 1 - 1 - - -
Italy 2 3 5 1 - 1 0 0 0
Americas 0 0 0 0 0 0 0 0 0
Asia 0 0 0 0 0 0 0 0 0
Other - Europe 0 0 0 0 0 0 0 0 0
Open-ended contract No. 3,331 849 4,180 3,273 832 4,105 3,300 847 4,147
Italy 3,331 849 4,180 3,273 831 4,104 3,300 845 4,145
Americas 0 0 0 0 0 0 0 0 0
Asia 0 0 0 0 1 1 0 2 2
Other - Europe 0 0 0 0 0 0 0 0 0
Total 3,333 852 4,185 3,274 832 4,106 3,300 847 4,147

Note: the Group does not employ employees on zero-hours contracts

Table 20. Total number of employees by type of employment and gender. [GRI 2-7]

Employees 2022 2021 2020
(headcount) u.m. Male Female Total Male Female Total Male Female Total
Full-time
employees
3,324 831 4,155 3,264 807 4,071 3,282 814 4,096
Part-time
employees
No. 9 21 30 10 25 35 18 33 51
Total 3,333 852 4,185 3,274 832 4,106 3,300 847 4,147

Table 21. Number of non-employee workers [GRI 2-8]

Professional category u.m. 2022 2021 2020
Temporary staff No. 2 3 0
Trainees 6 18 6
Other (*) 304 256 1
Total 312 277 7

(*) The category "Other" in 2022 includes non-employee workers for engineering support, systems engineers, maintenance, plant certification, postal service, transport, canteens, cleaning services and welcome service. In 2021, the category "Other" includes maintenance, certification, postal service, transport, canteens, cleaning services, and a coordinated and continuous collaboration. The total figure for the category "Other" is not available for 2020, but only non-employees with coordinated and continuous collaboration are considered.

Note: The total number of non-employees is an estimated figure and represents the number of non-employees who worked for the Company during the year.

2022 2021 2020
Employees Male Female Total Male Female Total Male Female Total
(headcount) No. % No % No. % No. % No % No. % No. % No % No. %
Senior
manageme
nt
48 1,1% 3 0,1% 51 1,2% 46 1,1% 4 0,1% 50 1,2% 51 1,2% 5 0,1% 56 1,4%
less than 30
years old
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
between 30
and 50
4 0,1% 0 0 4 0,1% 7 0,2% 1 0 8 0,2% 9 0,2% 4 0,1% 13 0,3%
over 50 44 1,1% 3 0,1% 47 1,1% 39 0,9% 3 0.1 42 1,0% 42 1,0% 1 0,0% 43 1,0%
Middle
manageme
nt
347 8,3% 63 1,5% 410 9,8% 351 8,5% 61 1,5% 412 10% 355 8,6% 62 1,5% 417 10,1
%
less than 30
years old
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
between 30
and 50
90 2,2% 20 0,5% 110 2,6% 99 2,4% 25 0,6% 124 3% 109 2,6% 26 0,6% 135 3,3%
over 50 257 6,1% 43 1,0% 300 7,2% 252 6,1% 36 0,9% 288 7% 246 5,9% 36 0,9% 282 6,8%
Office staff 2,91
1
69,6
%
78
6
18,8
%
3,69
7
88,3
%
2,84
2
69,2
%
76
7
18,7
%
3,60
9
87,9
%
2,85
3
68,8
%
78
0
18,8
%
3,63
3
87,6
%
less than 30
years old
200 4,8% 31 0,7% 231 5,5% 162 3,9% 23 0,6% 185 4,5% 165 4,0% 28 0,7% 193 4,7%
between 30
and 50
1,61
7
38,6
%
43
2
10,3
%
2,04
9
49% 1,63
1
39,7
%
43
3
10,5
%
2,06
4
50,3
%
1,66
7
40,2
%
44
6
10,8
%
2,11
3
51,0
%
over 50 1,09
4
26,1
%
32
3
7,7% 1,41
7
33,9
%
1,04
9
25,5
%
31
1
7,6% 1,36
0
33,1
%
1,02
1
24,6
%
30
6
7.4 1,32
7
32,0
%
Blue collar 27 0,6% 0 0 27 0,6% 35 0,9% 0 0 35 0,9% 41 1,0% 0 0 41 1,0%
less than 30
years old
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
between 30
and 50
12 0,3% 0 0 12 0,3% 18 0,4% 0 0 18 0,4% 23 0,6% 0 0 23 0,6%
over 50 15 0,4% 0 0 15 0,4% 17 0,4% 0 0 17 0,4% 18 0,4% 0 0 18 0,4%
Total 3,33
3
79,6
%
85
2
20,4
%
4,18
5
100% 3,27
4
79,7
%
83
2
20,3
%
4,10
6
100% 3,30
0
79,6
%
84
7
20,4
%
4,14
7
100%

Table 22. Employees by age, gender and level. [GRI 405-1]

Table 23. Number of new hires by age group, gender, and geographical area. [GRI 401-1]

2022 2021 2020
Number of new hires u.m. Male Female Total Male Female Total Male Female Total
Italy 338 66 404 226 20 246 138 11 149
less than 30 years old 238 34 272 176 16 192 116 8 124
between 30 and 50 85 32 117 48 4 52 21 2 23
over 50 15 0 15 2 - 2 1 1 2
Americas 0 0 0 0 0 0 0 0 0
less than 30 years old 0 0 0 0 0 0 0 0 0
between 30 and 50 0 0 0 0 0 0 0 0 0
over 50 0 0 0 0 0 0 0 0 0
Asia 0 0 0 0 0 0 0 0 0
less than 30 years old No. 0 0 0 0 0 0 0 0 0
between 30 and 50 0 0 0 0 0 0 0 0 0
over 50 0 0 0 0 0 0 0 0 0
Other - Europe 0 0 0 0 0 0 0 0 0
less than 30 years old 0 0 0 0 0 0 0 0 0
between 30 and 50 0 0 0 0 0 0 0 0 0
over 50 0 0 0 0 0 0 0 0 0
Total 338 66 404 226 20 246 138 11 149
less than 30 years old 238 34 272 176 16 192 116 8 124
between 30 and 50 85 32 117 48 4 52 21 2 23
over 50 15 - 15 2 - 2 1 1 2

Note: the calculation of the number of new hires also includes employees with a fixed-term pseudo pilot contract (192 for 2022, 167 for 2021 and 97 for 2020)

Inter-company transfers for 2022 included:

− 20 resources were recruited in ENAV from TS, divided between:

− 2 women of which 0 women aged < 30 years, 1 woman aged between 30 and 50 years and 1 woman aged > 50 years,

− 18 men of whom 0 men aged <30 years, 14 aged between 30 and 50 years and 4 men aged >50 years.

  • In TS, 23 ENAV resources were recruited:

  • 23 men of whom 0 men aged < 30 years, 6 men between 30 and 50 years and 17 men aged > 50 years.

Table 24. Number of employees who left the Group, by age, gender, and geographical area. [GRI 401-1]

Employees who left 2022 2021 2020
the Group u.m. Male Female Total Male Female Total Male Female Total
Italy 279 45 324 252 34 286 172 25 197
less than 30 years old 171 21 192 155 13 168 93 8 101
between 30 and 50 32 6 38 15 0 15 12 1 13
over 50 76 18 94 82 21 103 67 16 83
Americas 0 0 0 0 0 0 0 0 0
less than 30 years old 0 0 0 0 0 0 0 0 0
between 30 and 50 0 0 0 0 0 0 0 0 0
over 50 0 0 0 0 0 0 0 0 0
Asia 1 0 1 0 1 1 0 0 0
less than 30 years old 0 0 0 0 0 0 0 0 0
between 30 and 50 No. 0 0 0 0 0 0 0 0 0
over 50 1 0 1 0 1 1 0 0 0
Other - Europe 0 0 0 0 0 0 0 0 0
less than 30 years old 0 0 0 0 0 0 0 0 0
between 30 and 50 0 0 0 0 0 0 0 0 0
over 50 0 0 0 0 0 0 0 0 0
Total 280 45 325 252 35 287 172 25 197
less than 30 years old 171 21 192 155 13 168 93 8 101
between 30 and 50 32 6 38 15 0 15 12 1 13
over 50 77 18 95 82 22 104 67 16 83

Note: the calculation of the number of employees who left the Group also includes employees with a fixed-term pseudo pilot contract (192 for 2022, 167 for 2021 and 97 for 2020).

Furthermore, during 2022, 43 inter-group transfers were recorded, as follows:

23 resources left ENAV to be recruited in TS, specifically:

− 23 men of whom 0 men aged < 30 years, 6 men between 30 and 50 years and 17 men aged > 50 years.

For Techno Sky, 20 employees left to be hired by ENAV, comprising:

− 2 women, of whom: 0 women aged <30 years; 1 woman aged between 30 and 50 years; 1 woman aged >50 years.

− 18 men, of whom: 0 employees <30 years old; 14 employees between 30 and 50 years old; 4 employees >50.

Table 25. Turnover rate [GRI 401-1].

Turnover rate u.m. 2022 2021 2020
Male Female Total Male Female Total Male Female Total
Italy % 8.37 5.28 7.74 7.7 4.09 6.97 5.2 3.0 4.8
Americas 0 0 0 0 0 0 0 0 0
Asia 100 0 100 0 100 100 0 0 0
Other - Europe 0 0 0 0 0 0 0 0 0
Total 8.40 5.28 7.77 7.7 4.21 6.99 5.2 3.0 4.8

Table 26. Rate of new hires [GRI 401-1].

Rate of new hires 2022 2021 2020
u.m. Male Female Total Male Female Total Male Female Total
Italy 10.14 7.75 9.65 6.9 2.41 5.99 4.2 1.3 3.6
Americas % 0 0 0 0 0 0 0 0 0
Asia 0 0 0 0 0 0 0 0 0
Other - Europe 0 0 0 0 0 0 0 0 0
Total 10.14 7.75 9.65 6.9 2.4 5.99 4.2 1.3 3.6

Table 27. Number of hours of classroom and e-learning operational training by gender and category [GRI 404-1].

Training
hours by
2022 2021 2020
gender and
level
u.m. Male Female Total Male Female Total Male Female Total
Senior 0 0 0 3 0 3 0 0 0
management
Middle 108 48 156 354 0 354 112 32 144
management
Office staff Hours 112,031 13,950.5 125,981.5 105,577.5 8,223.5 113,801 96,586 3,092 99,678
Blue collar 140 0 140 200 0 200 363 0 363
Total 112,279 13,998.5 126,277.5 106,134.5 8,223.5 114,358 97,061 3,124 100,185

Table 28. Number of hours of classroom and e-learning training by gender and category [GRI 404-1].

Training 2022 2021 2020
hours
by
gender
and
level
u.m. Male Women Total Male Women Total Male Women Total
Senior 277 21 298 772 16 788 995 38 1,033
management
Middle
management 3,681 884 4,565 3,941 1,080 5,021 4,465 1,190 5,655
Office staff Hours 17,745.5 6,460.5 24,206 22,517 5,886 28,403 15,306 6,231 21,537
Blue collar 144 0 144 299 0 299 146 0 146
Total 21,847.5 7,365.5 29,213 27,529 6,982 34,511 20,912 7,459 28,371

Note: training refers to specialist managerial, legal and language training

Table 29. Number of hours of classroom and e-learning training in occupational health and safety by gender and category [GRI 404- 1].

Training
hours by
gender and
level
u.m. 2022 2021 2020
Male Female Total Male Female Total Male Female Total
Senior
management
235 8 243 132 0 132 32 0 32
Middle
management
2,367.00 374 2,741 670 46 716 448 52 500
Office staff Hours 21,914 4,347 26,261 7,587 574 8,161 7,256 493 7,749
Blue collar 104 0 104 96 0 96 356 0 356
Total 24,620 4,729 29,349 8,485 620 9,105 8,092 545 8,637

Table 30. Number of hours of classroom and e-learning environmental training [GRI 404-1].

Training hours by 2022 2021 2020
gender and level u.m. Male Female Total Male Female Total Male Female Total
Senior
management
0 0 0 0 0 0 45 8 53
Middle
management
7 1 8 34 49 83 186 30 216
Office staff Hours 339 48 387 169 28 197 928 108 1,036
Blue collar 0 0 0 0 0 0 10 0 10
Total 346 49 395 203 77 280 1,169 146 1,315
Table 31. Average hours of training. [GRI 404-1]
-------------------------------------------------- -- --
Hours of 2022 2021 2020
training
(classroom
and e
learning)
u.m. Male Female Total Male Female Total Male Female Total
Total number
of training
hours
provided to
employees
Hours 159,093 26,142 185,235 142,351 15,904 158,255 116,578 10,986 127,564
Total number
of employees
No. 3,333 852 4,185 3,274 832 4,106 3,300 847 4,147
Average
employee
training hours
Hours/no. 48 31 44 43 19 39 39 13 33
Total number
of training
hours
provided to
senior
management
Hours 512 29 541 908 17 925 1,072 46 1,118
Total number
of senior
managers
No. 48 3 51 46 4 50 51 5 56
Average
training hours
provided to
senior
management
Hours/no. 11 10 11 20 4 19 21 9 20
Total number
of training
hours
provided to
middle
management
Hours 6,163 1,307 7,470 5,001 1,175 6,176 5,211 1,304 6,515
Total number
of middle
managers
No. 347 63 410 351 61 412 355 62 417
Average
training hours
provided to
middle
management
Hours/no. 18 21 18 14 19 15 15 21 16
Total number
of training
hours
provided to
office staff
Hours 152,030 24,806 176,836 135,847 14,713 150,559 120,076 9,924 130,022
Total number
of office
workers
No. 2,911 786 3,697 2,842 767 3,609 2,853 780 3,633
Average
training hours
provided to
office staff
Hours/no. 52 32 48 48 19 42 42 12 35
Total number
of training
hours
provided to
blue collar
workers
Hours 388 0 388 595 0 595 875 0 875
Total number
of blue collar
workers
No. 27 0 27 35 0 35 41 0 41
Average
training hours
provided to
blue collar
workers
Hours/no. 14 0 14 17 0 17 21 0 21

Table 32. Number of ongoing training hours by gender.

Ongoing training hours 2022 2021 2020
by gender and category u.m. Male Female Total Male Female Total Male Female Total
Employees Hours 45,802 7,109 52,911 53,172 6,572 59,744 67,618 8,358 75,976

Table 33. Number of employees involved in ongoing training by gender.

Number
of
employees
u.m. 2022 2021 2020
involved by gender Male Female Total Male Female Total Male Female Total
Employees No. 1,946 302 2,248 1,769 241 2,010 1,854 261 2,115

Table 34. Number of ongoing operating unit training hours by gender.

Ongoing operating unit
training hours by gender
and category
u.m. 2022 2021 2020
Male Female Total Male Female Total Male Female Total
Employees Hours 78,385 9,214 87,599 65,041 12,389 77,430 19,591 3,621 23,212

Table 35. Number of employees involved in ongoing operating unit training by gender.

Number
of
employees
involved by gender and
category
2022 2021 2020
u.m. Male Female Total Male Female Total Male Female Total
Employees No. 1,625 191 1,816 440 65 505 307 48 355

Table 36. Number of new grievances with employees.

Number
of
pending
grievances
with
employees
u.m. 2022 2021 2020
Number of new grievances with employees No. 40 48 51

Table 37. Number of new grievances with employees.

Number of new grievances with employees u.m. 2022 2021 2020
Number of new grievances with employees No. 6 11 13

Table 38. Percentage of employees covered by collective bargaining agreements. [GRI 2-30]

Percentage
of
employees
covered
by
collective bargaining agreements
u.m. 2022 2021 2020
Percentage
of
employees
covered
by
collective bargaining agreements
% 100% 100% 99,95%

Note: Senior management is excluded from the calculation.

Table 39. Percentage of employees registered with a union.

Percentage of employees registered with a
union
u.m. 2022 2021 2020
Percentage of employees registered with a
union
% 61% 67% 68%

Note: senior management is excluded from the calculation

Table 40. Number of strikes.

Number of strikes u.m. 2022 2021 2020
Number of strikes No. 8 16 6

Table 41. Number of strike hours.

Number of strike hours u.m. 2022 2021 2020
Number of strike hours No. 163 240 84

Table 42. Number of recordable work injuries, injury rate and number of hours worked by employees [GRI 403-9].

Employees u.m. 2022 2021 2020
Male Female Total Male Female Total Male Female Total
Total recordable
injuries at work
3 2 5 6 1 7 10 2 12
Recordable injuries at
work (with the
exclusion of injuries
with serious
consequences)
No. 3 2 5 6 1 7 8 2 10
Number of injuries at
work with serious
consequences (with the
exclusion of deaths)
0 0 0 0 0 0 2 0 2
Deaths following
injuries at work
0 0 0 0 0 0 0 0 0
Number of hours
worked
No. 4,893,064 1,144,149 6,037,213 4,752,198 1,158,156 5,910,354 4,321,669 1,091,212 5,412,881
death rate resulting
from injuries at work
No. 0 0 0 0 0 0 0 0 0
death rate at work with
serious consequences
0 0 0 0 0 0 0.46 0 0.37
rate of recordable
injuries at work
0.61 1.75 2.36 1.26 0.86 1.18 2.31 1.83 2.22

Note: The indices are calculated as follows: Death rate resulting from injuries at work (no. deaths/no. of hours worked) x 1,000,000; Injury rate at work with serious consequences: (No. of injuries with serious consequences/No. of hours worked) x 1,000,000; Rate of recordable injuries at work: (No. of recordable injuries at work/No. of hours worked) x 1,000,000.

Commuting accidents are included among recordable and reported workplace accidents only if the transport was organised by the company.

Total hours worked by non-employees of the ENAV group in 2021 were estimated at 208,970 hours. The categories taken into account for the calculation of the estimated hours were as follows: maintenance and certification services, cleaning services and canteen services, postal services, and transportation services, as they were considered significant according to the exposure to the risk of occupational injury and categories that are consistently present from year to year. It should be noted that in February 2021, an accident episode of a non-employee worker, engaged in a construction site activity for the supply and installation of the new cabin under TWR at Alghero Airport, was recorded by the Group Prevention and Protection structure. The recordable occupational injury rate is 4.8.

The total number of hours worked by non-employees of the ENAV Group in 2022 was estimated at 292,328 hours.

The categories considered in calculating the estimated hours for 2022 were the same as in 2021, with the addition of the following: engineering support, systems engineers, welcome service, and trainees. It should be noted that in 2022, the Group's Prevention and Protection unit recorded two accidents involving two non-employee workers, the first engaged in a construction site activity at Linate Airport and the second in cleaning services. The recordable work injury rate of non-employees is 6.84.

Table 43. Number of hours of outside training in the classroom by category of recipient.

Training hours by category u.m. 2022 2021 2020
Private Customer 0 6,664 4,380
Business Customer Hours 17,575 0 0
Total 17,575 6,664 4,380

Table 44. Number of external participants involved in external classroom training by category of recipient.

Number of third parties involved by category u.m. 2022 2021 2020
Private Customer 0 145 55
Business Customer No. 295 0 0
Total 295 145 55

Table 45. Results of training for local development carried out in 2022.

Activities carried out 2022 2021 2020
Days
attended
Attendees Days
attended
Attendees Days
attended
Attendees
Apprenticeship Training 3,132 19 1,818 25 171 42
Teaching visits 41 1,100 0 0 0 0
Total 3,173 1,119 1,818 25 171 42

Note: In 2020 and 2021, educational visits and the intercultural project were suspended due to the health emergency.

Table 46. Annual total remuneration ratio [GRI 2-21]

2022 2021 2020
Ratio of the annual total remuneration of the person receiving the
highest remuneration to the median annual total remuneration of all
employees (excluding the aforementioned person)
15.05 12.56 12.38
Ratio of the percentage increase in the annual total remuneration of
the person receiving the highest remuneration to the median
percentage increase in the annual total remuneration of all
employees (excluding the aforementioned person)
4.72 0.57 3.40

Note: The total annual remuneration of employees consists of the Gross Annual Remuneration (RAL) and fringe benefits such as overtime, Performance Bonus, LTI and other allowances. The person receiving the highest remuneration is the CEO of ENAV S.p.A..

Table 47. Percentage of employees who received an evaluation of performances and of professional development [404-3]

2022 2021
Men Women Total Men Women Total Men Women Total
Number of Senior
management
48 3 51 46 4 50 51 5 56
Middle
management
347 63 410 351 61 412 355 62 417
employees
at 31/12
Office staff 2,911 786 3,697 2,842 767 3,609 2,853 780 3,633
Blue collar 27 - 27 35 - 35 41 - 41
Total 3,333 852 4,185 3,274 832 4,106 3,300 847 4,147
Number of
employees
who
received
Senior
management
46 3 49 43 4 47 46 4 50
Middle
management
69 9 78 - - - - - -
Office staff 1,215 461 1,676 968 404 1,372 955 401 1,356
an
evaluation
Blue collar - - - - - - - - -
Total 1,330 473 1,803 1,011 408 1,419 1,001 405 1,406
Senior
management
96% 100% 96% 93% 100% 94% 90% 80% 89%
Middle
management
20% 14% 19% - - - - - -
% Total Office staff 42% 59% 45% 34% 53% 38% 33% 51% 37%
Blue collar - - - - - - - - -
Total 40% 56% 43% 31% 49% 35% 30% 48% 34%

GOVERNANCE

Table 48. Numero totale degli individui all'interno degli organi di governo delle società36 suddivisi per gruppo di età e genere [GRI 405- 1]

Members of
the governing
2022 2021 2020
bodies Men Women Total Men Women Total Men Women Total
(headcount) No. % No. % No. % No. % No. % No. % No. % No. % No. %
less than
30 years old
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
between 30
and 50
years old
4 21 1 5 5 26 5 25 3 15 8 40 3 15 5 25 8 40
over 50
years old
8 42 6 32 14 74 8 40 4 20 12 60 9 45 3 15 12 60
Total 12 63 7 37 19 100 13 65 7 35 20 100 12 60 8 40 20 100

36 Board of Directors as at 31.12.2022 of ENAV, Techno Sky, IDS AirNav and D-Flight.

Table 49. Numero totale degli individui all'interno degli organi di controllo delle società37 suddivisi per gruppo di età e genere [GRI 405- 1]

Members of
the governing
2022 2021 2020
bodies Men Women Total Men Women Total Men Women Total
(headcount) No. % No. % No. % No. % No. % No. % No. % No. % No. %
less than
30 years old
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
between 30
and 50
years old
0 0 0 0 0 0 0 0 2 17 2 17 0 0 3 25 3 25
over 50
years old
8 67 4 33 12 100 8 67 2 17 10 83 8 67 1 8 9 75
Total 8 67 4 33 12 100 8 67 4 33 12 100 8 67 4 33 12 100

Table 50. Country-by-country reporting [GRI 207-4].

Group tax jurisdiction.

Dimensions u.m. 2022 2021 2020
Number of employees N 4,185 4,106 4,147
Tax-related data u.m. 2022 2021 2020
Revenue from sales to third parties 952,780,248 845,123,689 780,916,323
Revenue from inter-Company transactions
with other tax jurisdictions
270,138 306,418 459,163
Profit/loss before taxes 147,781,945 104,839,979 79,924,758
Tangible assets other than liquid assets and
cash equivalents
2,414,606,300 2,368,554,293 2,087,275,743
Income tax defined based on a cash basis 39,532,966 15,350,978 37,388,520
Income tax for companies accrued on
profits/losses
44,633,100 29,189,049 22,502,453

37 Board of Statutory Auditors as at 31.12.2022 of ENAV, Techno Sky, IDS AirNav and D-Flight.

It should be noted that in 2022, the calculation methodology Group Tax Jurisdiction was updated, whereby the value of Pre-tax Profit/Loss is derived from the consolidated. Tax jurisdiction Italy, with data relative to the following ENAV S.p.A. entities - Techno Sky S.r.l. - IDS AirNav S.r.l. and D-Flight S.r.l. whose main activities concern "Air traffic control/regulated market, ATC system maintenance, sale on non-regulated markets and UAV traffic control".

Dimensions u.m. 2022 2021 2020
Number of employees N 4,185 4,105 4,145
Tax-related data u.m. 2022 2021 2020
revenue from sales to third parties 952,431,844 844,051,944 778,224,700
revenue
from
inter-Company
transactions
with
other
tax
jurisdictions
270,138 306,418 459,163
Profit/loss before taxes 147,616,151 104,697,323 79,011,601
tangible assets other than liquid
assets and cash equivalents
2,346,675,520 2,306,012,830 2,031,761,584
income tax defined based on a cash
basis
39,567,685 15,253,362 37,195,978
income tax for companies accrued on
profits/losses
44,631,222 29,130,169 22,226,547

Tax jurisdiction Malaysia, with data related to the following entity ENAV Asia Pacific Sdn Bhd, whose main activities concern "sale on non-regulated markets"

Dimensions u.m. 2022 2021 2020
Number of employees N 0 1 2
Tax-related data u.m. 2022 2021 2020
revenue from sales to third parties 348,404 1,071,745 2,690,778
revenue
from
inter-Company
transactions with other tax jurisdictions
0 0 0
Profit/loss before taxes 3,205 198,662 991,945
tangible assets other than liquid assets
and cash equivalents
638,946 685,409 890,751
income tax defined based on a cash
basis
34,719 97,616 192,542
income tax for companies accrued on
profits/losses
1,878 58,880 275,906

Tax jurisdiction USA, with data related to the following entity ENAV North Atlantic LLC, whose main activities concern "holding"

Dimensions u.m. 2022 2021 2020
Number of employees N 0 0 0
Tax-related data u.m. 2022 2021 2020
revenue from sales to third parties 0 0 845
revenue from inter-Company
transactions with other tax
jurisdictions
0 0 0
Profit/loss before taxes -91,488 -56,006 -78,788
tangible assets other than liquid assets
and cash equivalents
67,291,834 61,856,054 54,623,408
income tax defined based on a cash
basis
0 0 0
income tax for companies accrued on
profits/losses
0 0 0

Table 51. Average payment period for suppliers.

Number of days for payment of suppliers (ENAV) u.m. 2022 2021 2020
Average payment period for suppliers 63 84.5 70.7
Average advance (delay) in relation to contractual conditions Days -34 -93.73 51.6
Number of days for payment of suppliers (Techno Sky) u.m. 2022 2021 2020
Average payment period for suppliers 39 40 40
Average advance (delay) in relation to contractual conditions Days -46 40.4 23.4
Number of days for payment of suppliers (ENAV Asia Pacific) u.m. 2022 2021 2020
Average payment period for suppliers 5 5 5
Average advance (delay) in relation to contractual conditions Days 0 0 0
Number of days for payment of suppliers (IDS AirNav) u.m. 2022 2021 2020
Average payment period for suppliers 42 23.6 27.3
Average advance (delay) in relation to contractual conditions Days -17 - 22 34.9
Number of days for payment of suppliers (D-Flight) u.m. 2022 2021 2020
Average payment period for suppliers Days 90 60 60
Average advance (delay) in relation to contractual conditions 30 40 24

Table 52. Negative social impacts in the supply chain and actions taken. [GRI 414-2]

Negative social impacts in the supply chain and actions taken
Type of evaluation Unit of
measurement
2022 2021 2020
No.
Number of suppliers assessed for social impacts No. 804 720 727
Number of suppliers identified as having significant actual and potential
negative social impacts
0 0 0
Percentage of suppliers identified as having significant actual and potential
negative social impacts with which improvements were agreed upon as a
result of assessment
0,00% 0,00% 0,00%
Percentage of suppliers identified as having significant actual and potential
negative social impacts with which relationships were terminated as a
result of assessment, and why
% 0,00% 0,00% 0,00%

Note: The values reported refer to the suppliers of the companies ENAV, Techno Sky and D-Flight, as they are subject to the Code of Public Contracts Legislative Decree 50/2016, through which the evaluation in question is carried out. The remaining companies, on the other hand, are not subject to the aforementioned Code and, therefore, do not carry out this type of evaluation.

Table 53. Governance structure and composition [GRI 2-9]

Structure and composition of ENAV's governance.

2020
Board of Directors
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body
Number of other
significant
assignments
and
commitment
s
held by
each
member
Nature of these
commitment
s
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Skills relevant to
the
impacts
of the
organisation
Director 1 FEMALE NO YES 3 0 NA NO NO YES
Director 2 MALE YES NO 3 1 Chair NO NO YES
Director 3 FEMALE NO YES 3 1 Director NO NO YES
Director 4 FEMALE NO NO 3 0 NA NO NO YES
Director 5 MALE NO YES 3 0 NA NO NO YES
Director 6 MALE NO YES 3 0 NA NO NO YES
Director 7 MALE NO YES 3 1 Chair of the Board
of Statutory
Auditors
NO NO YES
Director 8 FEMALE NO YES 3 2 Director NO NO YES
Director 9 MALE NO YES 3 1 Director NO NO YES
2021
Board of Directors
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body
Number of other
significant
assignments
and
commitment
s
held by
each
member
Nature of these
commitment
s
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Competencies
relevant to
the
impacts
of the
organisation
Director 1 FEMALE NO YES 3 0 NA NO NO YES
Director 2 MALE YES NO 3 0 NA NO NO YES
Director 3 FEMALE NO YES 3 1 Director NO NO YES
Director 4 FEMALE NO NO 3 0 NA NO NO YES
Director 5 MALE NO YES 3 0 NA NO NO YES
Director 6 MALE NO YES 3 0 NA NO NO YES
Director 7 MALE NO YES 3 1 Chair of the Board
of Statutory
Auditors
NO NO YES
Director 8 FEMALE NO YES 3 2 Director NO NO YES
Director 9 MALE NO YES 3 0 NA NO NO YES
2022
Board of Directors
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body
Number of other
significant
assignments
and
commitment
s
held by
each
member
Nature of these
commitment
s
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Competencies
relevant to the
impacts
of the
organisation
Director 1 Women NO YES 3 1 Board Member NO NO
Director 2 Men YES NO 3 0 - NO NO
Director 3 Women NO YES 3 1 Board Member NO NO
Director 4 Women NO NO 3 0 - NO NO
Director 5 Men NO YES 3 0 - NO NO
Director 6 Men NO YES 3 0 - NO NO
Director 7 Men NO YES 3 1 Chair of the
Board
of Statutory
Auditors
NO NO
Director 8 Women NO YES 3 2 Board Member NO NO
Director 9 Men NO YES 3 1 Board Member NO NO
2020 – 2021 – 2022
Control, Risks and Related Parties Committee
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body
Number of
other
significant
assignment
s and
commitme
nts
held by
each
member
Nature of these
commitments
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Competencies
relevant to the
impacts
of the
organisation
Director 1 MALE NO YES 3 1 Chair of the Board
of Statutory
Auditors
NO NO YES
Director 2 FEMALE NO NO 3 0 NA NO NO YES
Director 3 MALE NO YES 3 0 NA NO NO YES
2020 – 2021 – 2022
Remuneration and Appointments Committee
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body
Number of other
significant
assignments
and
commitment
s
held by
each
member
Nature of these
commitment
s
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Competencies
relevant to the
impacts
of the
organisation
Director 1 MALE NO YES 3 0 NA NO NO YES
Director 2 FEMALE NO NO 3 0 NA NO NO YES
Director 3 FEMALE NO YES 3 1 Chair of the Board
of Statutory
Auditors
NO NO YES
2020 – 2021 – 2022
Sustainability Committee
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body
Number of other
significant
assignments
and
commitment
s
held by
each
member
Nature of these
commitment
s
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Competencies
relevant to
the
impacts
of the
organisation
Director 1 MALE NO YES 3 1 Director NO NO Yes
Director 2 FEMALE NO YES 3 1 Director NO NO Yes
Director 3 FEMALE NO YES 3 2 Director NO NO YES

Structure and composition of Techno Sky's governance.

2020
Board of Directors
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body (years)
Number of other
significant
assignments
and
commitment
s
held by
each
member
Nature of these
commitment
s
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Competencies
relevant to
the
impacts
of the
organisation
Director 1 MALE YES NO 3 NO NO YES
Director 2 FEMALE NO NO 3 NO NO YES
Director 3 MALE NO NO 3 NO NO YES
2021
Board of Directors
Director 1 MALE YES NO 3 NO NO YES
Director 2 FEMALE NO NO 3 NO NO YES
Director 3 MALE NO NO 3 NO NO YES
2022
Board of Directors
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body (years)
Number of other
significant
assignments
and
commitment
s
held by
each
member
Nature of these
commitment
s
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Competencies
relevant to
the
impacts
of the
organisation
Director 1 Men YES 3 NO NO
Director 2 Women NO 3 NO NO
Director 3 Men NO 3 NO NO

Structure and composition of the governance of IDS AirNav

2020
Board of Directors
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body (years)
Number of other
significant
assignments
and
commitment
s
held by
each
member
Nature of these
commitment
s
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Competencies
relevant to
the
impacts
of the
organisation
Director 1 MALE YES NO 3 NO NO YES
Director 2 FEMALE NO NO 3 NO NO YES
Director 3 MALE NO NO 3 NO NO YES
2021
Board of Directors
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body (years)
Number of other
significant
assignments
and
commitment
s
held by
each
member
Nature of these
commitment
s
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Competencies
relevant to
the
impacts
of the
organisation
Director 1 MALE YES NO 3 NO NO YES
Director 2 FEMALE NO NO 3 NO NO YES
Director 3 MALE NO NO 3 NO NO YES
2022
Board of Directors
First and Last
Names
Gender Executive
Director
Independent
Director
Duration of
term of
office
of the
governing
body (years)
Number of other
significant
assignments
and
commitment
s
held by
each
member
Nature of these
commitment
s
Membership of
under
represented
social
groups
Representation
of
Stakeholders
Competencies
relevant to
the
impacts
of the
organisation
Director 1 Men YES 3 NO NO
Director 2 Men NO 3 NO NO
Director 3 Women NO 3 NO NO

Table 54. Compliance with laws and regulations during the reporting period. [GRI 2-27]

Significant instances of non-compliance with laws and regulations in the
reporting period
2022 2021 2020
Cases for which fines were imposed 0 1 0
Cases for which
non-pecuniary penalties were incurred
no. 0 0 0
Fines for non-compliance with laws and regulations that were paid during the reporting period and a breakdown of this total
2022 2021 2020
Penalties for non-compliance with laws occurring in no. 0 1 0
the current reporting period 0 146,095 0
Penalties for non-compliance with laws that occurred
in previous reporting periods
no. 0 0 0
0 0 0

Note: Significant monetary sanction means a sanction of more than € 20,000

Table 55: Benefits provided to full-time employees that are not provided to temporary or part-time employees [401-2]

2022 2021 2020
Life insurance YES YES YES
Healthcare YES YES YES
Insurance cover in the event of disability and invalidity YES YES YES
Parental leave YES YES YES
Pension contributions YES YES YES
Shareholding NO NO NO

Notes: Life insurance is only provided for Executives.

The indicator refers to the ENAV Group as a whole.

Annex 2 - GRI Content Index and correlation tables

Domain of
Legislative
Decree
254/2016
No. Material issues GRI aspect
Company 1 Quality of service
2 Responsible supplier management GRI 414: Supplier Social Assessment
3 Relations with industry
organisations, institutions and
associations
GRI 2-28: Membership Associations
4 Safety GRI 416: Customer Health and Safety
GRI 404: Training and Education
5 Security
6 Technological innovation and
digitalisation
Personnel38 7 Adequacy, enhancement and
development of human capital
GRI 404: Training and education
8 Diversity and inclusion GRI 401: Employment
GRI 405: Diversity and equal opportunity
GRI 406: Non-discrimination
9 Corporate welfare GRI 401: Employment
GRI 402: Labour/management relations
10 Health and Safety in the workplace GRI 403: Occupational Health and Safety
Anti 11 Corporate Governance and
Integrity
GRI 205: Anti-corruption
Corruption 12 Economic and financial value
creation
GRI 201: Economic performance
GRI 207: Tax
Environment 13 Energy consumption and climate
change
GRI 302: Energy
GRI 305: Emissions
39 14 Electromagnetic emissions GRI 413: Local communities

Table: Aspects of Legislative Decree 254/2016, material topics and GRI aspects

38 Regarding the "Personnel" aspect, it should be noted that D-Flight data are not separately detailed because the Company has 7 seconded employees hired by ENAV, Techno Sky and IDS AirNav, which are in addition to 3 seconded employees hired by Telespazio S.p.A./Leonardo S.p.A.

39 Regarding the "Environment" aspect, ENAV Asia Pacific, by virtue of the characteristics of the company (1 office) is not considered relevant for environmental impacts. It should be noted that d-flight workers on secondment operate in the head office of Techno Sky.

Domain of
Legislative
Decree
254/2016
No. Material issues GRI aspect
15 Waste management GRI 306: Waste
Human
rights40
16 Responsible supplier management GRI 414: Supplier Social Assessment
17 Diversity and inclusion GRI 406: Non-discrimination

40 As concerns the "Human rights" aspect, the topic is covered transversally within the scope of other material issues.

Table: GRI Content Index

Statement of use Enav S.p.A. has reported in accordance with the GRI Standards
for the period 1st January 2022 – 31st December 2022
GRI 1 used GRI 1: Foundation 2021
Applicable GRI Sector Standard(s) Not Applicable
Omission
GRI
STANDARDS
Disclosure Reference page Require
ment(s)
Omitted
Reason Explanation
General Disclosure
2-1 Organisational Details 6 - 7; 62
ENAV's registered office is
in Via Salaria 716, Rome,
Italy
2-2 Entities included in the
organisation's sustainability
reporting
7
2-3 Reporting period, frequency
and contact points
Reporting is annual. For
information or comments
on this document, please
submit a request to
[email protected]
2-4 Revision of information 177
2-5 External assurance 179
GRI 2: General
Disclosures
2-6 Activities, value chain and
other business relationships
8 – 11; 125 - 127
2-7 employees 136 - 137
2-8 Non-employees 137
2-9 Structure and composition of
governance
96 – 101; 152 - 155
2-10 Appointment and selection
of the highest governing body
102
2-11 Chair of the highest
governing body
The president is not a
senior executive of the
Society
2-12 Role of the highest governing
body in impact management
control
98 - 101; 103 - 107
Disclosure Reference page Omission
GRI
STANDARDS
Require
ment(s)
Omitted
Reason Explanation
2-13 Delegation of responsibility
for impact management
103 - 106
2-14 Role of the highest
governance body in sustainability
reporting
14 -15; 96 - 98; 103 -
107
2-15 Conflicts of interest 107 - 109
2-16 Disclosure of criticalities 103 - 113
2-17 Collective knowledge of the
highest governing body
106 - 109
2-18 Performance assessment of
the highest governing body
106 - 107
2-19 Remuneration regulations 121 - 123
2-20 Remuneration determination
procedure
121 - 123
2-21 Total annual salary ratio 147
2-22 Sustainable development
strategy statement
4 -5
2-23 Policy commitment 108 - 113
2-24 Integration of policy
commitments
108 - 113
2-25 Processes to remedy
negative impacts
108 - 113
2-26 Mechanisms for requesting
clarification and raising concerns
108 - 113
2-27 Compliance with laws and
regulations
156
2-28 Membership in associations 63 - 69
2-29 Approach to Stakeholder
engagement
58 - 59
2-30 Collective bargaining
agreements
145
Material issues
Disclosure Reference page Omission
GRI
STANDARDS
Require
ment(s)
Omitted
Reason Explanation
GRI 3: Material
Topics
3-1 Process for determining
material topics
175 - 176
3-2 List of material topics 175 - 176
Economic performance
GRI 3: Material
Topics
3-3 Management of material
topics
25 – 26; 175 - 176
GRI 201:
Performance
economiche
2016
201-1 Directly generated and
distributed economic value
26
Anti-corruption
GRI 3: Material
Topics
3-3 Management of material
topics
108 - 113; 175- 176
GRI 205: Anti
corruption
2016
205-1 Options evaluated for risks
related to corruption
In the three-year period
2020-2022,
the
risks
related to corruption were
assessed in the context of
the
risk
assessment
process
in
100%
of
processes.
205-3 Verified episodes of
corruption and actions taken
From the analyses and
investigations conducted,
no
acts
of
corruption
(active or passive) were
discovered
during
the
2020-2022 period.
Tax
GRI 3: Material
Topics
3-3 Management of material
topics
114 – 118; 124; 175 -
176
207-1 Approach to taxes 124
GRI 207: Taxes
2019
207-2 Fiscal governance, control
and risk management
114 - 118; 124
207-3 Involvement of the
stakeholders and management of
tax concerns
124
207-4 Country by country
reporting
148 - 150
Energy
Omission
GRI
STANDARDS
Disclosure Reference page Require
ment(s)
Omitted
Reason Explanation
GRI 3: Material
Topics
3-3 Management of material
topics
37 - 38; 175- 176
GRI 302: Energy 302-1 Energy consumed in the
organisation
37 – 38; 130
2016 302-3 Energy intensity 131
Emission
GRI 3: Material
Topics
3-3 Management of material
topics
29-31; 35-41; 116; 118-
120; 175 - 176
305-1 Direct greenhouse gas
(GHG) emissions (Scope 1)
29-31; 35-41; 131
305-2 Indirect greenhouse gas
(GHG) emissions (Scope 2)
29-31; 35-41; 131
GRI 305: 2016
Emissions
305-3 Other indirect greenhouse
gas (GHG) emissions (Scope 3)
29-31; 35-41; 132
305-4 Intensity of greenhouse gas
(GHG) emissions
132
305-5 Reduction of GHG
emissions
133
Waste
GRI 3: Material
Topics
3-3 Management of material
topics
29 -31; 44; 175 - 176
GRI 306: 2020 306-1 Waste generation and
significant waste-related impacts
44
306-2 Management of significant
waste-related impacts
44
waste 306-3 Waste generated 44; 133
306-4 Waste diverted from
disposal
44; 133 - 134
306-5 Waste directed to disposal 44; 133 - 134
Employment
GRI 3: Material
Topics
3-3 Management of material
topics
71 – 72; 76 – 79; 175 -
176
Omission
GRI
STANDARDS
Disclosure Reference page Require
ment(s)
Omitted
Reason Explanation
401-1 New hires and turnover 139 - 141
GRI 401
Employment
2016
401-2 Benefits provided to full
time employees that are not
provided to temporary or part
time employees
87 - 90; 155
Relationships between workers and management
GRI 3: Material
Topics
3-3 Management of material
topics
71 – 72; 76 – 79; 93 -
94; 175 - 176
GRI 402:
Relationships
between
workers and
management
2016
402-1 Minimum notice period for
operating changes
With reference to
organisational changes
and the relative minimum
notification period, each
country of the Group
respects the local
regulations of reference in
that area.
More specifically:
- for ENAV, the significant
organisational changes
are notified in compliance
with the autonomy and
liability of the Company as
disciplined by art.7 "rights
to information" of CCNL.
These notifications are
made with appropriate
notice;
- for Techno Sky and IDS,
notifications regarding
organisational changes
are made according to
provisions of law and/or
collective contracts and/or
union agreements. The
notice period for the
disclosures are specified
according to provisions of
law and/or collective
contracts and/or union
agreements.
Omission
GRI
STANDARDS
Disclosure Reference page Require
ment(s)
Omitted
Reason Explanation
Occupational health and safety
GRI 3: Material
Topics
3-3 Management of material
topics
91 - 92; 175 - 176
403-1 Health and safety at work
management system
91 - 92; 167 - 169
403-2 Identification of hazards,
risk assessment and surveys on
incidents
114 – 118
403-3 Occupational medicine
services
91 - 92
GRI 403:
Occupational
health and
safety 2018
403-4 Participation and
consultation of workers and
notification concerning
occupational health and safety
91 - 92
403-5 Worker training concerning
occupational health and safety
91 - 92
403-6 Promotion of worker health 91 - 92
403-7 Prevention and mitigation
of the impacts in terms of
occupational health and safety in
business relationship
91 - 92
403-9 Injuries at work 146
3-3 Management of material
topics
No incidents of
discrimination occurred in
the ENAV Group in the
three-year period 2020-
2022.
Training and instruction
GRI 3: Material
Topics
3-3 Management of material
topics
79 - 86; 175 - 176
GRI 404:
Training and
instruction
2016
404-1 Average hours of annual
training per employee
141 - 144
404-2 Programmes for upgrading
employee skills and transition
assistance programmes
79 - 86
Disclosure Reference page Omission
GRI
STANDARDS
Require
ment(s)
Omitted
Reason Explanation
404-3 Percentage of employees
who received an evaluation of
performances and of professional
development
148
Diversity and equal opportunities
GRI 3: Material
Topics
3-3 Management of material
topics
73 - 75; 175 - 176
GRI 405:
Diversity and
equal
opportunities
2016
405-1 Diversity in governing
bodies and between employees
138; 148 - 149
Non-discrimination
GRI 3: Material
Topics
3-3 Management of material
topics
73 - 75; 175 - 176
GRI 406: Non
discrimination
2016
406-1 Episodes of discrimination
and corrective measures adopted
No incidents of
discrimination occurred in
the ENAV Group in the
three-year period 2020-
2022.
Local communities
GRI 3: Material
Topics
3-3 Management of material
topics
43; 175 - 176
GRI 413: Local
communities
2016
413-2 Activities with significant
negative impacts, potential and
current, on local communities
43
Social evaluation of suppliers
GRI 3: Material
Topics
3-3 Management of material
topics
125 - 126; 175 - 176
GRI 414: Social
evaluation of
suppliers
414-2 Negative social impacts in
the supply chain and actions
taken
152
Health and safety of customers
GRI 3: Material
Topics
3-3 Management of material
topics
12 – 13; 128 - 129; 175 -
176
GRI 416: Health
and safety of
416-1 Assessment of the impacts
on the health and safety by
product and service categories
All activities of ENAV and
Techno Sky. This indicator
does not apply to IDS
AirNav and D-Flight as the
Omission
GRI
STANDARDS
Disclosure Reference page Require
ment(s)
Omitted
Reason Explanation
customers
2016
characteristics of the
product and services
offered by nature do not
have an impact on the
Health and Safety of
customers.
Security
GRI 3: Material
Topics
3-3 Management of material
topics
128 - 129; 175 - 176
Technological innovation and digitalisation
GRI 3: Material
Topics
3-3 Management of material
topics
45 - 48; 175 - 176
Quality of service
GRI 3: Material
Topics
3-3 Management of material
topics
45 - 48; 51 - 56; 128 - 129;
175 - 176

Table: TCFD (Task Force on Climate-related Financial Disclosure) recommendations

Thematic area TCFD recommendation Disclosure Page
▪ Describe the Board of Directors' oversight of
climate-related risks and opportunities
Governance – Role of the Board of Directors in
managing impacts
103
Governance ▪ Describe the role of management in
assessing and managing climate-related
risks and opportunities
Governance – Role of the Board of Directors in
managing impacts
103
Strategy ▪ Describe the climate-related risks and
opportunities
that
the
Company
has
identified in the short, medium and long
term
Governance – Possible impacts of climate change
on core business
118 - 120
▪ Describe the impact of climate-related risks
and
opportunities
on
the
Company's
activities, strategy and financial planning
Governance – Possible impacts of climate change
on core business
118 - 120
▪ Describe the resilience of the Company's
strategy, taking into consideration different
climate-related
scenarios,
including
a
temperature increase scenario of 2° C or less
Governance – Possible impacts of climate change
on core business
118 - 120
Risk
management
▪ Describe the processes implemented by the
organisation to identify and assess climate
change risks
Governance - Managing risks and opportunities,
Possible impacts of climate change on business
114 - 120
▪ Describe the organisation's implemented
processes for managing climate change risks
Governance - Managing risks and opportunities,
Possible impacts of climate change on business
114 - 120
▪ Describe how processes to identify, assess
and manage climate change risks are
integrated into the Company's overall risk
management
Governance - Managing risks and opportunities,
Possible impacts of climate change on business
114 - 120
Metrics and
targets
▪ Disclose the metrics used by the Company to
assess
climate
change
risks
and
opportunities in line with its strategy and
risk management process
Planet – The commitment to decarbonisation of
the Group's activities
Governance – Possible impacts of climate
change on core business
32; 118 -
120
▪ Disclose Scope 1, Scope 2 and, where
applicable, Scope 3 greenhouse gas (GHG)
emissions and related risks
Planet – The commitment to decarbonisation of
the Group's activities
32
▪ Describe the targets used by the Company to
manage
climate-related
risks
and
opportunities and performance against
those targets
Planet – The commitment to decarbonisation of
the Group's activities
The 2021-2024 Sustainability Plan
32; 170

Annex 3 - Group Management Systems, Certifications and Attestations ENAV

ENAV Group Management System:

  • ENAV Quality Management System (197 documents, including procedures, guidelines and operating instructions)
  • Techno Sky Quality Management System (107 documents, including procedures, guidelines and operating instructions)
  • ENAV Group Occupational Health and Safety Management System (20 documents, including procedures and operating instructions)
  • ENAV Management System for the Prevention of Corruption (7 procedures)
  • IDS AirNav Quality Management System (24 documents, including procedures and operating instructions)
  • ENAV Group Security Management System (42 documents, including rules, procedures, guidelines and operating instructions)
  • ENAV Safety Management System (18 documents, including procedures and guidelines)
  • ENAV Asia Pacific Quality Management System (3 procedures)
  • ENAV Group Environmental management system (15 procedures)

ENAV certifications and attestations

  • ISO 9001:2015 certification for the Quality Management System issued by an accredited certification body
  • ISO/IEC 27001:2013 certification for the Safety Management System, issued by an accredited certification body for the part relating to information security
  • ISO 37001:2016 certification for the Anti-corruption Management System issued by an accredited certification body
  • ISO 45001:2018 certification for the Occupational Health and Safety Management System issued by an accredited certification body
  • Certification as a provider of air traffic management services and air navigation services ("Service Provider Certification"), issued by ENAC pursuant to Regulation (EU) No. 373/2017 for ATS, ATFM, ASM, AIS, MET, CNS and FPD services
  • Certification as a training organisation for air traffic controllers, issued by ENAC pursuant to Commission Regulation (EU) 2015/340
  • Certification as a training organisation for flight information service operators, issued by ENAC under ENAC Regulation "Flight Information Service Operator License (FIS)"
  • Certification as a training organisation for personnel providing meteorological services for air navigation, issued by ENAC under ENAC Regulation "Requirements for personnel in the provision of meteorological services for air navigation"
  • Certification as an organisation for the planning of instrumental flight procedures, issued by the General Civil Aviation Authority (GCAA) of the United Arab Emirates (UAE) pursuant to Civil Aviation Advisory Publication CAAP 68 Instrument Flight Procedure Design Requirements
  • Certificate of Approval for the Company for the management of continuous airworthiness and the maintenance company pursuant to EU Regulation 1321/2014 (air fleet).

Techno Sky certifications and certificates

  • ISO 9001:2015 certification for the Quality Management System issued by an accredited certification body
  • ISO/IEC 27001:2013 certification for the Safety Management System, issued by an accredited certification body for the part relating to information security
  • ISO 45001:2018 certification for the Occupational Health and Safety Management System issued by an accredited certification body
  • AQAP 2110/160 certification for the Quality Management System, issued by the Ministry of Defence
  • Certification of qualification to perform Public works pursuant to DPR 207/2010
  • Accreditation of LAT Centre No. 15 as calibration laboratory pursuant to the international standard UNI CEI EN ISO/IEC 17025:2018, issued by Accredia
  • Certificate of Conformity with Regulation (EU) 2015/2067 (F-GAS) for the installation, maintenance, or repair of fixed equipment for refrigeration, air-conditioning and heat pumps containing fluorinated gases with greenhouse effects
  • Certification in Capability Maturity Model Integration for Development V2.0 (CMMI-DEV) for the development of products and services that certifies the degree of maturity reached in software development (Maturity level 2).

IDS AirNav certifications

  • ISO 9001:2015 certification for the Quality Management System issued by an accredited certification body
  • ISO/IEC 27001:2013 certification for the Safety Management System, issued by an accredited certification body for the part relating to information security
  • ISO 45001:2018 certification for the Occupational Health and Safety Management System issued by an accredited certification body
  • ISO 14001:2015 certification for the Environmental Management System issued by an accredited certification body
  • Certification in Capability Maturity Model Integration for Development V2.0 (CMMI-DEV) for the development of products and services that certifies the degree of maturity reached in software development (Maturity level 3)

D-Flight certifications:

▪ ISO 45001:2018 certification for the Occupational Health and Safety Management System issued by an accredited certification body.

Annex 4 – 2021-2024 Sustainability Plan

Objectives KPIS Targets Year Target achieved
in 2022
Percentage of core suppliers involved in the assessment (against
ESG criteria) of total ENAV core suppliers
Assessment launch date 2071 77% of core suppliers
assessed against ESG
criteria
Supplier evaluation against ESG criteria 75% 2072
100% 2073
ESG Rating
(As per the LTI 2023 plan)
Rating identification
Assessment on rating (Gap analysis + Action Plan)
Assessment 2021
Improvement of the ESG Rating S&P Rating (+30% compared
to 2021 score)
2023
Increase in training delivered to ENAV
Group employees on issues that include
aspects related to Legislative Decree
231/2001 and the Code of Ethics, Anti-
Bribery and Anti-Corruption, Fraud and
Whistleblowing.
Percentage of increase in hours of training delivered to
employees compared to 2020 (hours delivered by Internal Audit
in 2020 = 4 hours 50 minutes).
For 2023, ownership of training topics related to Anti Bribery and
Anti Corruption and Fraud will be shared by the IA and ICRM
units.
+5% 2021 V 2022 targets
exceeded
+6.5% 2022
+7.5% 2023
Definition of a model for measuring the
economic, social and environmental
impacts generated by the Company's
strategic sustainability initiatives
Development of measurement model Presentation date 2023
Objectives KPIs Targets Year Target
achieved in
2022
Monitoring of standards regarding health
and safety in the workplace by means of Retention of ISO 45001:2018 certification.
retaining ISO 45001:2018 certification
Certificate renewal 2023
Anti-corruption management systems Obtain ISO 37001 certification
(indicator as per the short-term incentive
policy and MBO 2021 for AD and Managers
with Strategic Responsibilities)
Certificate obtained 2021 V
Retention of ISO 37001 certification Certificate renewal 2023
Publication of the media policy Publication of the policy on the company intranet Publication date 2021 V
Drafting of the regulations on harassment I
and abuse in the workplace
Publication of the regulations on the company intranet Publication date 2021 V
Objectives KPIs Targets Year Target
achieved in
2022
Obtain EASI (Integrated Sustainability
Corporate Ecosystem) certification
NEW ·
Obtain certification Certification date 2023
Feasibility assessment for the adoption of
the ISO 56002 standard for the management
of innovation processes in businesses NEW .
Elaboration of feasibility study and cost/opportunity assessment Assessment date 2023
Feasibility assessment for certification
according to UNI/PdR 125:2022 Reference
Practice (Gender Equality Policies)
NEW
Elaboration of feasibility study and cost/opportunity
assessment
Assessment date 2023
Feasibility assessment for certification
according to ISO 30415:2021 (Diversity &
Inclusion).
Elaboration of feasibility study and cost/opportunity
assessment
Assessment date 2023
Objectives KPIs Targets Year Target
achieved in
2022
towers by means of a new airport ATM Testing of the system at each airport involved as per the yearly
schedule
Testing date 2021 LIN - Test at Rome
i Ciampino in
December 2022
Advanced automation of major control 2021 TV
2022 CIA V
platform
(Electronic
strip/Radar !
presentation)
2023 FCO
2024 OLB
Approach sequence optimisation system I
(Arrival Manager - AMAN)
Testing of systems applied at Malpensa and Fiumicino airports Testing dates 2022 RM V i Implementation in
December 2022
2023 MI
TOC-HAL: remotisation project of diagnosis
on remote site equipment to enable the
centralisation of control and the
optimisation of maintenance interventions
Testing of systems on all 10 islands as planned Testing dates 2023
METAR AUTO' weather automation project
(weather observation system with automatic
messaging in the event of a contingency)
Testing of "METAR AUTO" automated weather systems at the 23
designated airports
Testing dates 2021 V
Objectives KPIS Targets Year Target
achieved in
2027
Integration of approaches (transfer of radar
approaches from certain airports to their
respective control centres of reference)
Testing and implementation of Transfers of Verona to Milan,
Trieste to Padua, Bari to Brindisi, Lamezia Terme to Rome
Testing dates 2021 V
Testing and entry into operation of Transfer of Naples to Rome 2022 V Transfer
completed on
19/05/2022
Testing and entry into operation of Transfer of Turin to Milan,
Venice to Padua, Florence to Rome
2023
Testing and entry into operation of Transfer of Genoa to Milan,
Palermo to Rome, Bologna to Padua
2024
Development of research and innovation
activities related to the SDGs
Completion of 3 Enav Group research and innovation projects
enabling the use of drones for environmental monitoring and
civil infrastructure monitoring.
Date of project closure
report
2024
Research and development of artificial
intelligence and machine
learning
algorithms, to be executed
NEW
Performance
Computing
CIOUG
environments, functional to the Group's
core and non-core activities and to
sustainability issues
Number of algorithms developed on corporate business issues Development of 4
algorithms
2024
Objectives KPIs Targets Year Target
achieved in
2022
Internal Communication Plan on the
development of sustainability culture
Number of internal communications projects to be launched
over the year
2021 V
% growth in entries on Follow me (1,051,578 visits in December
2020)
+20% 2021 V
Convey the image of ENAV as an benchmark
player in the industry in the fight against - Number of followers on the LinkedIn
innovation.
climate change and sustainable digital (20,300 followers on ENAV LinkedIn in March 2021) +10% 2021 V
Development of materiality analysis i
according to the Double Materiality con NEW .
Identification of the new list of relevant topics Approval date 2024
GHG Report processing GHG Report publication Publication date 2024
Further boost to external communication or
sustainability topics
Making the short film on sustainability topics Publication date 2023
Objectives KPIS Targets Year Target
achieved in
2022
Dissemination of sustainability topics to
the younger generation through a
"Generational Report"
Production of the "Generational Report" Presentation date 2024
Integrated corporate performance reporting Presentation of the Integrated Annual Report template to Top
Management
Presentation date 2024
Objectives KPIs Targets Year Target
achieved in
2022
Definition of the ENAV "Purpose" Publication of the purpose Presentation date 2021 V
To develop initiatives aimed at promoting
the inclusion of all employees, regardless
of age, gender, ethnicity, religion, sexual
orientation and people living with
disabilities
Number of people involved in the pilot project to improve the
position of people living with disabilities
20 2021 V
To develop further the culture of
sustainability by means of increased
Engagement in focus on in-country staff At least 3 focus groups 2021 √
engagement in the in-country Group
organisational units
Number of in-country ambassadors identified 10 2021 V
Development of platform to convert performance bonus into
welfare instruments
Presentation date 2021 V
Improving the quality of life of employees
by means of targeted welfare initiatives
Measurement of the work-life balance satisfaction index,
including by means of new working arrangements (e.g. agile Analysis presentation date
working)
2022 V The results of
the
measurement
were presented
on 20/02/2022
Objectives KPIs Targets Year Target
achieved in
2022
Assessment on diversity management, gap
analysis and action plan
(Indicator as per the short-term incentive
policy and MBO 2021 for AD and DIRS)
Preparation of assessment, gap analysis and action plan Work
presentation
2021 V
Operational training
(Objectives that fall within the two ESG
Hours of operational training
(73,000 hours in 2019)
78,000 2021 V
Sustainability Linked Term Loans, taken out
in October 2020)
82,000 2022 V Targets exceeded
(> 94,000 hours)
Acquiring new talent with sensitivity to ESG
issues
Construction and validation of a new selection tool to support
the assessment of the value framework on ESG issues during the
talent acquisition process.
Carrying out the initial
selection using the new
tool
2023
Objectives KPIs Targets Year Target
achieved in
2022
Bringing women closer to the core business
professions, with specific reference to air
traffic control and maintenance activities, by Launch of the outreach project
means of raising women's awareness of
technical-operational roles
Launch date 2022 √ Several activities
commenced in
2022 (more
details in the
People chapter)
In external selections, the proportion of
25% (comply or explain)
women in operational roles must be at least Minimum participation of the female population 25% 2021 V
In internal assessments aimed at filling new
operational positions, the proportion of
women must be at least 20% (comply or
explain)
Minimum participation of the female population 20% 2021 V
In internal assessments aimed at filling new
corporate positions, the proportion of
women must be at least 50% (comply or
explain)
Minimum participation of the female population 50% 2021 √
Objectives KPIs Targets Year AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND
Target
achieved in
2022
Achieve Group Carbon Neutrality (Scope -23% CO2 2021 The 2022 emissions
and Scope 2) by reducing emissions and the
purchase of carbon credits for the
proportion that cannot be reduced
As per the LTI plan for the 2020-2022 cycle)
Percentage of reduction of CO2 emissions per year compared to
the total emissions produced in 2019 (38,816 t - market-based)
and purchase of carbon credits
- 70% CO2 emissions(Scope
1 and 2) + Carbon
Neutrality
2022 V offset - for the purpose
of achieving Carbon
Neutrality - will take
place following the
approval of this Report
Abatement of electromagnetic 50% 2022 V As of 31/12/2022,
transmitted by means of optimisation on I
navigation instruments
Percentage of NDB decommissioning 90% 2024 50% of NDBs have
been discontinued
Further development of the "Plastic-Free
project aimed at gradual reduction in single
ise plastics at all company offices
Tons of single-use plastics reduced at sites (total ENAV
consumption in 2019: 14.2 t)
1.5 t 2021 V
31% 2071
Further development of the project to
replace the company car fleet with
Percentage of company
fleet
with
replaced
car
45% 2022 V As of 31/12/2022.
45% of the
electric/hybrid/plug-in vehicles electric/hybrid/plug-in vehicles 73% 2023 Company car fleet
has been replaced
80% 2024
CO2 emissions assessment: extension t
scope 3
(Indicator as per the short-term incentive
policy and MBO 2021 for AD and DIRS)
Presentation of the assessment to top management NEW .
Presentation date
2021 V
Objectives KPIs Targets Year Target
achieved in
2022
Preparation of the Science-based Target
Indicator as per the short-term incentive
policy and MBO 2021 for AD and DIRS)
Obtained certification from SBTi Certification date 2021 V
Authorisation, testing and entry into force:
· Tri-generation plant, Rome ACC.
· LED internal lighting system - Padua ACC, Rome ACC and
Headquarters
· Air conditioning system - Rome ACC
Radar photovoltaic plant - MASSERIA 33 kW, Photovoltaic Plants in
LAMPEDUSA 37 kW, GENOA 17 kW, CATANIA 20 kW, NAPLES
75 kW.
100% 2022 V Plants activated by
December 2022
(more details in the
Planet chapter)
Implementation of energy efficiency
projects
Authorisation, testing and entry into force:
· Prototype use of eco-fuels for emergency GE
· Forli, Brancasi, APT Brindisi Photovoltaic Plant ACADEMY
· Elimination of 1 boiler (Ciampino ACC)
100% 2023
Authorisation, testing and entry into force:
· Air conditioning system - Naples BT
· Air conditioning system - Bari BT
· Air conditioning system - Malpensa BT
Conversion of 40 emergency GEs to eco-fuels
NEW .
Photovoltaic plant - Ustica
Elimination of 2 boilers (Bari, Malpensa)
100% 2024
Objectives KPIS Targets Year Target
achieved in
2022
Preparation of the Science-based Target
Indicator as per the short-term incentive
policy and MBO 2021 for AD and DIRS)
Obtained certification from SBTi Certification date 2021 V
Authorisation, testing and entry into force:
· Tri-generation plant, Rome ACC.
· LED internal lighting system - Padua ACC, Rome ACC and
Headquarters
· Air conditioning system - Rome ACC
Radar photovoltaic plant - MASSERIA 33 kW, Photovoltaic Plants in
LAMPEDUSA 37 kW, GENOA 17 kW, CATANIA 20 kW, NAPLES
75 kW.
100% 2022 V Plants activated by
December 2022
(more details in the
Planet chapter)
Implementation of energy efficiency
projects
Authorisation, testing and entry into force:
· Prototype use of eco-fuels for emergency GE
· Forli, Brancasi, APT Brindisi Photovoltaic Plant ACADEMY
· Elimination of 1 boiler (Ciampino ACC)
100% 2023

Annex 5 - Materiality analysis, methodological note and reporting boundary

Materiality analysis41

2022 was characterised by the new approach to materiality, dictated by the Global Reporting Initiative (GRI) 2021 reporting standard, built around the concept of impact42. The impacts of the ENAV Group have been defined through an in-depth analysis of the reference context - also drawing on the experience in nonfinancial reporting and in the Stakeholder management process of the ENAV Group - from the analysis of the Business Plan and the Sustainability Plan as well as from the analysis of the main public reference sources and best practices. This process was also carried out through the involvement of all the organisational structures of the Parent Company, the newly established ESG Steering Committee and the main Stakeholders of the ENAV Group. Materials were defined as those topics that reflected the Company's most significant impact on the economy, the environment, people and human rights.

The table below shows the impacts associated with the material issues43:

IMPACTS MATERIAL ISSUES GRI ASPECT
Maintaining high performance levels related to the
quality of air navigation assistance services that
enable people's mobility
Quality of service
Promotion of responsible behaviour and verification
of suppliers' compliance with the Group's ethical
principles to support ENAV's supply chain resilience
Responsible supplier
management
Supplier Social Assessment
(414)
Development of synergies with civil aviation bodies,
institutions and associations in order to realise a
common vision for the harmonisation of the
European air traffic management system
Relations with
industry organisations,
institutions and
associations
Membership Associations
(2-28)
Maintenance of safety levels of air navigation and air
traffic management services through the prevention
of possible degradation/failure of the performance of
one or more components (People, Procedures,
Equipment) of the functional system such as to
impact on the provision of Air Navigation Services
Safety Customer Health and
Safety (416)
Training and Education
(404)
Adoption of appropriate security measures to protect
the confidentiality, integrity and availability of
managed information data, in order to prevent
negative impacts on operations and business
Security
Actions to disseminate the culture of safety in the
workplace, aimed at the prevention of occupational
accidents and diseases
Health and Safety in
the workplace
Occupational Health and
Safety (403)

41 In compliance with the European common enforcement priorities for 2022 annual financial reports, issued by ESMA on 28 October 2022.

42 Impacts may be actual or potential, negative or positive, short-term or long-term, intentional or unintentional, reversible or irreversible 43 With respect to the material topics reported in the CNFS 2021, the material topics 'Sound Governance' and 'Anti-Corruption and Corporate Integrity' were integrated into the material topic 'Corporate Governance and Integrity', the material topic 'Quality of Human Capital' was expanded into 'Adequacy, Enhancement and Development of Human Capital', and the material topic 'Protection and well-being of employees' was changed to 'Corporate Welfare'. In addition, some material topics were reworded as follows: 'Health and safety of employees' (2021) amended to 'Health and Safety in the workplace'; 'Diversity, Inclusion and Equal Opportunities' (2021) amended to 'Diversity and Inclusion'; 'Responsible Supply Chain Management" (2021) amended to 'Responsible Supplier Management'.

IMPACTS MATERIAL ISSUES GRI ASPECT
Development of technological and digital solutions
for the improvement of air navigation services
Technological
innovation and
digitalisation
Creating professional excellence and enhancing and
improving the skills of employees through training
and professional development plans
Adequacy,
enhancement and
development of
human capital
Training and Education
(404)
Creating an inclusive and fair working environment in
order to prevent discrimination or abuse in the
Company and offer equal opportunities in all
evaluation processes
Diversity and inclusion Employment (401)
Diversity and Equal
Opportunity (405)
Non-discrimination (406)
Supporting work-life balance and promoting
corporate welfare initiatives to enhance people's
well-being
Corporate welfare Employment (401)
Labor/Management
Relations (402)
Ethical business conduct and transparent disclosure
of information about the Company's operations in
order to prevent situations of non-compliance with
applicable legislation of any kind, including anti
corruption legislation
Corporate Governance
and Integrity
Anti-corruption (205)
Creation of financial economic value for the benefit of
Stakeholders, including through proper tax
management
Economic and
financial value
creation
Economic Performance
(201)
Tax (207)
Efficiency of energy consumption for the operation of
assets and commitment to reducing and offsetting
climate gas emissions in order to mitigate the Group's
impact on climate change
Energy consumption
and climate change
Energy (302)
Emissions (305)
Commitment to the optimisation of Communication,
Navigation and Surveillance (CNS) equipment - also
through participation in international tables at which
new standards are defined - in order to promote the
containment of electromagnetic emissions generated
in the provision of related services
Electromagnetic
emissions
Local Communities (413)
Commitment to limiting the impact on ecosystems by
favouring the adoption of recovery of waste
generated by the Company's activities
Waste management Waste (306)

Note on methodology

The ENAV Group has prepared the Consolidated Non-Financial Statement (hereinafter also referred to as "Statement", "Sustainability Report" or "Report") in accordance with the provisions of Article 5(3)(b) of Legislative Decree No.254, dated 30 December 2016 (hereinafter "Decree"), as amended. The document constitutes a separate report from the Report on Operations.

The Statement, prepared pursuant to articles 3 and 4 of the Decree, and in accordance with the Decree, contains information on the Company's impact on five thematic areas, namely the environment, personnel management, social impacts, human rights and the fight against active and passive corruption and bribery. Reporting reflects the principles of the GRI Sustainability Reporting Standards (accuracy, balance, clarity, comparability, completeness, timeliness, verifiability and sustainability context44).

The Statement was drawn up in accordance with the GRI Standards published by the Global Reporting Initiatives (GRI Standards - "in accordance with" option), the independent authoritative body which defines models for non-financial reporting. Disclosures and indicators within the text are given in the GRI "Content Index" (Annex 2 "GRI Content Index and Correlation Tables").

It should be noted that where the Group considered it unnecessary to adopt policies related to several areas referred to in Legislative Decree 254/2016, this is linked to the existence of effective corporate practices which do not require it to adopt specific policies on the above-mentioned areas. For this reason it should be noted that the term "Policy" refers to documents that are formalised and approved.

Any changes to information published in previous reporting years have been appropriately noted in this CNFS.

This CNFS meets the demands of EU Regulation 852/2020 and the Delegated Act relating to Article 8 of the aforementioned Regulation regarding activities, capital expenditures and operating expenses associated with eco-sustainable activities, as reported in the relative paragraph "The EU Taxonomy".

This document was approved by ENAV Board of Directors on 15 March 2023.

In compliance with Legislative Decree 254/2016, this Non-Financial Statement, with the exception of the disclosures relating to the indicators summarised in the table "TCFD (Task Force on Climate-related Financial Disclosure) Recommendations" and the content of the paragraph "The EU Taxonomy", has been subjected to limited review in accordance with the "International Standard on Assurance Engagements ISAE 3000 (Revised) - Assurance Engagements Other than Audits or Reviews of Historical Financial Information", issued by the International Auditing and Assurance Standards Board (IAASB), by EY S.p.A. Furthermore, it should be noted that the quantitative indicators that do not refer to any general or topic-specific disclosure of the GRI Standards, reported on the pages indicated in the Content Index, are not subject to limited review by EY S.p.A.

The 2022 Consolidated Non-Financial Statement, as well as those for 2021, 2020, 2019, 2018 and 2017, are available on the Group's website (www.enav.it).

44 See the chapter "Stakeholders" and "Annex 5 - Materiality analysis, methodological note and reporting boundary".

Scope of reporting

The qualitative and quantitative information contained in the Consolidated Non-Financial Statement refers to the performances of the ENAV Group (hereinafter also referred to as "the Group") for the year ended on 31 December 2022. The frequency of reporting is annual and the reporting period of this document is the same as that of the Annual Financial Report. In addition, to help the reader better compare and contextualise the information herein, the data for the years 2021 and 2020 have been included and appropriately indicated.

This non-financial statement includes data and information referring to the "the ENAV Group", namely the set of companies composed of the Parent Company, ENAV S.p.A. and its subsidiaries, consolidated on a lineby-line basis: Techno Sky S.r.l., ENAV Asia Pacific Sdn Bhd, ENAV North Atlantic LLC, D-Flight and IDS AirNav. It should be noted that the Company ENAV España Control Aereo S.L.U, acquired in January 2020 in order to take part in a tender for the provision of terminal air traffic management services, has been excluded from the scope of reporting. Said Company is no longer operative and was liquidated in March 2021. In addition, on 9 February 2021, the liquidation proceedings were concluded with regards to the Sicta Consortium, which is included not reported in this NFS.

Please note that the terms "ENAV" and "the Company" refer exclusively to the Parent Company ENAV S.p.A.

Any restrictions to this scope have been appropriately indicated in the table "Scope of the material issues identified" (Annex 2). In any case, these limitations do not impair the comprehension of the performance and representativeness of the information.

AUDIT COMPANY REPORT

Enav S.p.A.

Independent auditor's report on the consolidated disclosure of nonfinancial information in accordance with article 3, par. 10, of Legislative Decree December 30, 2016 n. 254 and with article 5 of Consob Regulation adopted with Resolution n. 20267 of January 18, 2018

EY S.p.A. Via Lombardia, 31 00187 Roma

Tel: +39 06 324751 Fax: +39 06 324755504 ey.com

Independent auditor's report on the consolidated disclosure of nonfinancial information in accordance with article 3, par. 10, of Legislative Decree December 30, 2016, n. 254 and with article 5 of Consob Regulation adopted with Resolution n. 20267 of January 18, 2018

(Translation from the original Italian text)

To the Board of Directors of Enav S.p.A.

We have been appointed to perform a limited assurance engagement pursuant to article 3, paragraph 10, of Legislative Decree December 30, 2016, n. 254 (hereinafter "Decree") and article 5 of Consob Regulation adopted with Resolution n. 20267 of January 18, 2018, on the consolidated disclosure of non-financial information of Enav S.p.A. and its subsidiaries (hereinafter "Enav Group" or "Group") for the year ended on December 31, 2022 in accordance with article 4 of the Decree and approved by the Board of Directors on March 15, 2023 (hereinafter "DNF"). Our limited assurance engagement does not cover the information included in the paragraph "The EU Taxonomy" of the DNF, that are required by art.8 of the European Regulation 2020/852.

Responsibilities of Directors and Board of Statutory Auditors for the DNF

The Directors are responsible for the preparation of the DNF in accordance with the requirements of articles 3 and 4 of the Decree and the "Global Reporting Initiative Sustainability Reporting Standards" defined by GRI – Global Reporting Initiative (hereinafter "GRI Standards"), identified by them as a reporting standard.

The Directors are also responsible, within the terms provided by law, for that part of internal control that they consider necessary in order to allow the preparation of the DNF that is free from material misstatements caused by fraud or not intentional behaviors or events.

The Directors are also responsible for identifying the contents of the DNF within the matters mentioned in article 3, par. 1, of the Decree, considering the business and the characteristics of the Group and to the extent deemed necessary to ensure the understanding of the Group's business, its performance, its results and its impact.

The Directors are also responsible for defining the Group's management and organization business model, as well as with reference to the matters identified and reported in the DNF, for the policies applied by the Group and for identifying and managing the risks generated or incurred by the Group.

The Board of Statutory Auditors is responsible, within the terms provided by the law, for overseeing the compliance with the requirements of the Decree.

EY S.p.A. Sede Legale: Via Meravigli, 12 – 20123 Milano Sede Secondaria: Via Lombardia, 31 – 00187 Roma Capitale Sociale Euro 2.525.000,00 i.v. Iscritta alla S.O. del Registro delle Imprese presso la CCIAA di Milano Monza Brianza Lodi Codice fiscale e numero di iscrizione 00434000584 - numero R.E.A. di Milano 606158 - P.IVA 00891231003 Iscritta al Registro Revisori Legali al n. 70945 Pubblicato sulla G.U. Suppl. 13 - IV Serie Speciale del 17/2/1998 Iscritta all'Albo Speciale delle società di revisione Consob al progressivo n. 2 delibera n.10831 del 16/7/1997

A member firm of Ernst & Young Global Limited

Auditor's independence and quality control

We are independent in accordance with the ethics and independence principles of the International Code of Ethics for Professional Accountants (including International Independence Standards) (IESBA Code) issued by the International Ethics Standards Board for Accountants, based on fundamental principles of integrity, objectivity, professional competence and diligence, confidentiality and professional behavior. Our audit firm applies the International Standard on Quality Control 1 (ISQC Italia 1) and, as a result, maintains a quality control system that includes documented policies and procedures regarding compliance with ethical requirements, professional standards and applicable laws and regulations.

Auditor's responsibility

It is our responsibility to express, on the basis of the procedures performed, a conclusion about the compliance of the DNF with the requirements of the Decree and of the GRI Standards. Our work has been performed in accordance with the principle of "International Standard on Assurance Engagements ISAE 3000 (Revised) - Assurance Engagements Other than Audits or Reviews of Historical Financial Information" (hereinafter "ISAE 3000 Revised"), issued by the International Auditing and Assurance Standards Board (IAASB) for limited assurance engagements. This principle requires the planning and execution of work in order to obtain a limited assurance that the DNF is free from material misstatements. Therefore, the extent of work performed in our examination was lower than that required for a full examination according to the ISAE 3000 Revised ("reasonable assurance engagement") and, hence, it does not provide assurance that we have become aware of all significant matters and events that would be identified during a reasonable assurance engagement.

The procedures performed on the DNF were based on our professional judgment and included inquiries, primarily with company's personnel responsible for the preparation of the information included in the DNF, documents analysis, recalculations and other procedures in order to obtain evidences considered appropriate.

In particular, we have performed the following procedures:

    1. analysis of the relevant matters in relation to the activities and characteristics of the Group reported in the DNF, in order to assess the reasonableness of the selection process applied in accordance with the provisions of article 3 of the Decree and considering the reporting standard applied;
    1. analysis and evaluation of the criteria for identifying the consolidation area, in order to evaluate its compliance with the provisions of the Decree;
    1. comparison of the economic and financial data and information included in the DNF with those included in the Group's consolidated financial statements;
    1. understanding of the following aspects:
    2. o Group's management and organization business model, with reference to the management of the matters indicated in the article 3 of the Decree;
    3. o policies adopted by the Group related to the matters indicated in the article 3 of the Decree, results achieved and related key performance indicators;
    4. o main risks, generated or suffered, related to the matters indicated in the article 3 of the Decree.

With regard to these aspects, we obtained the documentation supporting the information contained in the DNF and performed the procedures described in item 5. a) below

  1. understanding of the processes that lead to the generation, detection and management of significant qualitative and quantitative information included in the DNF. In particular, we have conducted interviews and discussions with the management of Enav S.p.A. and we have performed limited documentary evidence procedures, in order to collect information about the processes and procedures that support the collection, aggregation, processing and transmission of non-financial data and information to the management responsible for the preparation of the DNF.

Furthermore, for significant information, considering the Group activities and characteristics:

  • at Group level
    • a) with reference to the qualitative information included in the DNF, and in particular to the business model, policies implemented and main risks, we carried out inquiries and acquired supporting documentation to verify its consistency with the available evidence;
    • b) with reference to quantitative information, we have performed both analytical procedures and limited assurance procedures to ascertain on a sample basis the correct aggregation of data.
  • for Enav S.p.A., that we have selected based on its activities and relevance to the consolidated performance indicators, we have carried out remote interviews during which we have had discussions with management and have obtained evidence about the appropriate application of the procedures and the calculation methods used to determine the indicators.

Conclusion

Based on the procedures performed, nothing has come to our attention that causes us to believe that the DNF of the Enav Group for the year ended on December 31, 2022 has not been prepared, in all material aspects, in accordance with the requirements of articles 3 and 4 of the Decree and the GRI Standards.

Our conclusions on the DNF of the Group do not refer to the information included in the paragraph "The EU Taxonomy" of the DNF itself, that are required by art.8 of the European Regulation 2020/852.

Rome, March 28, 2023

EY S.p.A. Signed by: Riccardo Rossi, Auditor

This report has been translated into the English language solely for the convenience of international readers.

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